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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
` )
`Google LLC, )
` )
` Petitioner, )
` )
` vs. )IPR2022-01411
` )IPR2022-01412
`WAG Acquisition, L.L.C., )IPR2022-01413
` )
` Patent Owner. )
`_____________________________)
`
` CORRECTED TRANSCRIPT
`
` REMOTE DEPOSITION OF WILLIAM LEO HOARTY
` Deponent testifying from Morgan Hill, California
` Monday, August 21, 2023
` Volume I
`
`Stenographically Reported By:
`Melissa M. Villagran, RPR
`CSR No. 12543
`Job No. 6056498
`PAGES 1 - 103
`
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`Page 1
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`Petitioner's Exhibit 1103
`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
`
`_____________________________
` )
`Google LLC, )
` )
` Petitioner, )
` )
` vs. )IPR2022-01411
` )IPR2022-01412
`WAG Acquisition, L.L.C., )IPR2022-01413
` )
` Patent Owner. )
`_____________________________)
`
` CORRECTED TRANSCRIPT
`
` REMOTE DEPOSITION OF WILLIAM LEO HOARTY
` Deponent testifying from Morgan Hill, California
` Monday, August 21, 2023
` Volume I
`
`Stenographically Reported By:
`Melissa M. Villagran, RPR
`CSR No. 12543
`Job No. 6056498
`PAGES 1 - 103
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`Veritext Legal Solutions
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`Page 1
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`Petitioner's Exhibit 1103
`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
`
`_____________________________
` )
`Google LLC, )
` )
` Petitioner, )
` )
` vs. )IPR2022-01411
` )IPR2022-01412
`WAG Acquisition, L.L.C., )IPR2022-01413
` )
` Patent Owner. )
`_____________________________)
`
` REMOTE DEPOSITION OF WILLIAM LEO HOARTY,
`Volume I, taken on behalf of Petitioner with all
`participants appearing remotely via videoconference
`and the Deponent testifying from Morgan Hill,
`California, beginning at 9:07 a.m. and ending at
`12:40 p.m. on Monday, August 21, 2023, before
`Melissa M. Villagran, RPR, Certified Shorthand
`Reporter No. 12543.
`
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`Petitioner's Exhibit 1103
`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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`A L L A T T E N D E E S A P P E A R I N G R E M O T E L Y
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`F o r P e t i t i o n e r :
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` C O O L E Y
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` B Y : E A M O N N G A R D N E R
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` A t t o r n e y a t L a w
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` 1 1 4 4 1 5 t h S t r e e t , S u i t e 2 3 0 0
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` D e n v e r , C o l o r a d o 8 0 2 0 2
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` 8 5 8 . 5 5 0 . 6 0 0 8
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` E g a r d n e r @ c o o l e y . c o m
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`F o r P a t e n t O w n e r :
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` L I S T O N A B R A M S O N
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` B Y : R O N A L D A B R A M S O N
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` M I C H A E L L E W I S
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` A t t o r n e y a t L a w
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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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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0003
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`
`
` INDEX
`
`DEPONENT EXAMINATION
`
`WILLIAM LEO HOARTY
`
`Volume I
`
` BY MR. GARDNER 6
`
` BY MR. GARDNER 96
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` EXHIBITS
`
`DEPOSITION PAGE
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`Exhibit 1101 Deposition from July 6, 2023 15
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`Exhibit 1102 Deposition from August 3rd, 2023 15
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`Exhibit 1594 '594 Patent 12
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`Exhibit 1636 '636 Patent 12
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`Exhibit 1824 '824 Patent 13
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0004
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`
`
` PREVIOUSLY MARKED EXHIBITS
`
`NUMBER PAGE
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`Exhibit 2006 10
`
`Exhibit 2007 10
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`Exhibit 1006 68
`
`Exhibit 2002 78
`
` INFORMATION REQUESTED
`
` (None.)
`
` INSTRUCTION NOT TO ANSWER
`
` (None.)
`
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0005
`
`
`
` Morgan Hill, California; Monday, August 21, 2023
`
` 9:07 a.m.
`
` WILLIAM LEO HOARTY,
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`having been administered an oath, was examined and
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`testified as follows:
`
` EXAMINATION
`
`BY MR. GARDNER:
`
` Q Mr. Hoarty, can you state your full name for 09:07:56
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`the record.
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` A For the -- excuse me.
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` For the record, my full name is William Leo
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`Hoarty.
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` Q And, Mr. Hoarty, where are you located today? 09:08:04
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` A Today I'm in my home in Morgan Hill,
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`California.
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` Q Is there anyone else in the room with you
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`today?
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` A Nobody is in the room with me. I am alone. 09:08:17
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` Q Before we get started, Mr. Hoarty, I just
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`want to reflect on the record that Petitioner Google
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`served a notice for this deposition on August 7th
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`stating that the deposition would be recorded by
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`stenographic audio and video means. 09:08:43
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`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0006
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` Petitioner Google then scheduled a
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`videographer for the deposition today. And not
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`until shortly before the deposition did the patent
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`owner WAG raise any objections or any issues to
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`that. 09:09:12
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` MR. GARDNER: Is that correct, Mr. Abramson?
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` MR. ABRAMSON: That's correct that we raised
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`an objection -- we have raised an objection to video
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`recording.
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` MR. GARDNER: Today, correct? 09:09:26
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` MR. ABRAMSON: Today.
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`BY MR. GARDNER:
`
` Q Now, Mr. Hoarty, you've been deposed before,
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`correct?
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` A Yes, sir. 09:09:35
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` Q Approximately how many times have you been
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`deposed?
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` A I believe approximately 20.
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` Q You have also been through multiple recent
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`depositions, correct? 09:09:47
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` A Correct.
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` Q So is it fair to say that you have a good
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`understanding of how depositions proceed and the
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`general rules governing depositions?
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` A Correct. 09:09:58
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0007
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` Q In that case, I won't spend everybody's time
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`going through deposition basics. But I do want to
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`remind you that we both need to do our best to not
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`talk over each other, especially because we're doing
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`this over the Zoom conferencing system. 09:10:16
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` Is that fair?
`
` A That's fair.
`
` Q Also, I will try to ask the best questions I
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`can today. But I'm sure from time to time I might
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`ask something that is unclear. If I do that, I ask 09:10:30
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`that you seek clarification.
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` Is that fair?
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` A That's fair.
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` Q And if you answer a question without seeking
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`clarification, I will assume that you understood the 09:10:40
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`question.
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` Is that fair?
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` A That's fair.
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` Q Is there any reason, such as medications or
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`health condition, that you feel you cannot answer 09:10:52
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`questions accurately today?
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` A No. No problem.
`
` Q Do you have any materials with you today?
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` A I have my deposition documents, the two of
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`them, and the exhibits of this matter. 09:11:06
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0008
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` Q When you say "deposition documents," what do
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`you mean by deposition documents?
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` A I wrote two declarations for this matter
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`covering the three patents, so the -- at issue.
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` Q I see. 09:11:25
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` And just to clarify, so when -- I think you
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`had said depositions. But did you mean
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`declarations?
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` A I did. I'm sorry. I've only had one cup of
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`coffee. But I'll hurry up -- I'll hurry up on the 09:11:36
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`second cup so I'll get my words in order. My
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`apologies.
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` Q Sounds good.
`
` The documents you have, are those printed
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`documents, or do you have them in electronic form? 09:11:47
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` A I have them in electronic form on a screen
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`next to me, just on my left.
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` Q Do you have any printed materials with you?
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` A I do not.
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` Q Do you have any -- do you currently have any 09:11:58
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`files opened on your computer?
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` A I do.
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` Q What files do you have opened?
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` A My declarations, the two of them, and then
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`the exhibits that go to this matter. 09:12:14
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0009
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` Q Do you have any other programs open on your
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`computer other than the Zoom chat that you are --
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` A No. Everything else -- Zoom -- the Zoom
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`application is running. Everything else is shut
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`down except for the PDF reader that has the 09:12:34
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`documents in the matter.
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` Q And just to clarify for the record, you had
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`said that you have your two declarations open and
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`available to you; is that correct?
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` A Yes. 09:12:54
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` Q One of those declarations is Exhibit 2002; is
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`that correct?
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` A Exhibit 2007 is one. I'm sorry. Let me
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`memorize -- Exhibit 2006 and 2007 are my exhibit
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`numbers for my two declarations. 09:13:17
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` Q You said Exhibit 2006.
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` Can you double-check that to see if it's
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`2002?
`
` A Sure. I may have to ask for assistance from
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`counsel. Let me bring up my -- my rest of -- let me 09:13:36
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`bring up the folder that they're in.
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` This is Google. I'm sorry. 2002 is the
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`exhibit for Patents '826 and -- '824 and '636. My
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`apologies.
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` I have too many documents open. I will 09:14:15
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0010
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`straighten this out. My apologies.
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` Q No need to apologize. I just want to make
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`sure we're on the same page.
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` All right.
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` So I just want to get this into the record, 09:14:26
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`and we'll try to make it as quickly as possible.
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` So you understand that the -- you are here to
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`testify today about the expert declarations, those
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`two expert declarations that you submitted in the
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`Google or in the IPRs that were filed by Google, 09:14:45
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`correct?
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` A Correct.
`
` Q All right.
`
` And those two declarations cover three
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`patents, correct? 09:15:00
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` A Correct.
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` Q And the first is U.S. Patent No. 9729594.
`
` Can we call that the '594 patent for short?
`
` A Yes, of course.
`
` Q And the declaration that you submitted on the 09:15:17
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`'594 patent, that would be Exhibit 2007, correct?
`
` A Correct.
`
` Q The other two patents are U.S. Patent
`
`No. 9762636.
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` Can we refer to that as the '636 patent 09:15:37
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0011
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`today?
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` A Yes.
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` Q And U.S. Patent No. 9742824, and can we refer
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`to that as the '824 patent today?
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` A Yes. 09:15:51
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` Q Exhibit 2002, I think you already said is the
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`declaration that you provided for the IPRs that are
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`related to both the '824 and the '636 patents; is
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`that correct?
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` A Correct. 09:16:08
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` Q And it's just a single identical declaration
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`for both the '824 and the '636 patent IPRs, correct?
`
` A It's the same document, correct.
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` Q Now, for -- for the purposes of the
`
`deposition, we premarked and introduced the '594 09:16:30
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`patent as Exhibit 1594. We introduced the '636
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`patent as Exhibit 1636. And we introduced the '824
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`patent as 1824.
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` (Exhibit 1594 was marked for
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` identification and is attached
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` hereto.)
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` (Exhibit 1636 was marked for
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` identification and is attached
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` hereto.)
`
` ///
`
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0012
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`BY MR. GARDNER:
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` Q My understanding, Mr. Hoarty, is you have 09:17:01
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`copies available to you for the 594636 and '824
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`patents; is that correct?
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` A That is correct.
`
` Q What did you do to prepare for today's
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`deposition? 09:17:20
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` A I reviewed my two declarations. I reviewed
`
`the -- the asserted patents in the matter.
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` Q When you say the two asserted patents in the
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`matter, what are you refer --
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` A No. I didn't say two patents. I said the 09:17:38
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`asserted -- the other patents that were from
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`the -- asserted in this matter, Exhibits 1002
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`through 1008.
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` Q Any other documents that you reviewed?
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` A I have -- I reviewed the Dr. Polish 09:18:01
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`declaration, Exhibit 2002, and the patents
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`themselves, Exhibit 1001, which is the '594 patent.
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`And then, of course, the two you just cited, '824,
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`'636.
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` Q Maybe I'll ask a better question to get us 09:18:24
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`Petitioner's Exhibit 1103
`Google LLC v. WAG Acquisition, IPR2022-01413
`Page 0013
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` Did you review any documents outside of
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`exhibits or declarations that are already introduced
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`into this matter?
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` A No, I did not. 09:18:41
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` Q Sir, you also submitted declarations in other
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`IPR proceedings that are related to some of the same
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`patents, correct?
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` A Correct.
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` Q And you were deposed in relation to those 09:18:57
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`other IPR proceedings; is that correct?
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` A Correct.
`
` MR. GARDNER: Mr. Abramson, I don't know the
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`best way to do this, but I had premarked a copy of
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`Mr. Hoarty's July 6, 2023 deposition as Exhibit 1101 09:19:11
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`and a copy of Mr. Hoarty's August 3rd, 2023
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`deposition as Exhibit 1102.
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` How would you like to handle allowing
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`Mr. Hoarty to have access -- have access to those
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`documents? 09:19:44
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` MR. ABRAMSON: You can put them through the
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`Google -- through the Zoom chat, I suppose.
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` COURT REPORTER: Can we go off the record for
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`a minute.
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` MR. GARDNER: Yeah, let's do that. 09:20:00
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` (Exhibit 1101 was marked for
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` identification and is attached
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` (Exhibit 1102 was marked for
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` hereto.)
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` (Recess.)
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`BY MR. GARDNER:
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` Q Mr. Hoarty, you've been provided a copy of
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`Exhibit 1101. 09:27:03
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` A Yes.
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` Q Can you open that document?
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` A Give me one more second, and I'll be able to
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`do that.
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` Okay. I have it open. 09:27:41
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` Q And Exhibit 1101 is a copy of your deposition
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`from July 6, 2023, correct?
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` A It appears to be, yes.
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` Q And during that deposition, you answered
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`questions honestly, correct? 09:27:54
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` A Yes, that's correct.
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` Q And you stand by the testimony you provided
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`during that deposition, correct?
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` A I believe so.
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` Q I'm hopeful that I will save us all time by 09:28:04
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`not having to recover all of the subject matter that
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`you went through during that deposition, but I want
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`to confirm, Mr. Hoarty, that you adopt your
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`testimony at --
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` MR. ABRAMSON: Hold on. I'm going to object 09:28:23
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`insofar as this transcript is not -- is not signed.
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` MR. GARDNER: First, Mr. Abramson, you can
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`note an objection to form, but I'm going to proceed
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`forward.
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` MR. ABRAMSON: I object that the 09:28:43
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`deposition -- the transcript is -- is not signed.
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`And I object to the extent -- that this question,
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`whether he adopts it or not, is beyond the scope of
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`his direct testimony in this case.
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` Object. 09:29:00
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` MR. GARDNER: Okay.
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` MR. ABRAMSON: My objection is noted.
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` You may proceed.
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`BY MR. GARDNER:
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` Q Mr. Hoarty, do you adopt your testimony from 09:29:07
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`that IPR just the same as you would provide the same
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`testimony today if I asked you the same questions?
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` MR. ABRAMSON: Objection. Those questions
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`are beyond the scope of this direct examination in
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`this case. 09:29:23
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` THE DEPONENT: I -- I don't know how to
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`answer because I haven't -- I haven't -- I'd have to
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`review what I said. I think in the intervening
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`month, I perhaps could be more concise or -- in one
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`answer or another. 09:29:44
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` But without reviewing this, I would be unable
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`to say that I'm going to -- say the same thing today
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`if you asked me the same question. Although the
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`intent will be the same and my opinions will remain
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`the same, I think you'll find -- I can perhaps 09:30:00
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`better -- better -- more clearly respond to your
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`questions than several months ago.
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`BY MR. GARDNER:
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` Q And did you -- have you since that deposition
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`reviewed those deposition transcripts? 09:30:14
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` A Actually, I have not. I'm sorry to say. I
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`did not.
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` Q Let me just ask you again, for Exhibit 1101,
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`for your July 6, 2023 deposition, you answered
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`questions during that deposition honestly, correct? 09:30:34
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` A I did.
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` Q And you stand by your testimony, correct?
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` MR. ABRAMSON: Objection; beyond the scope of
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`direct.
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` THE DEPONENT: Again, I'd like to -- in 09:30:44
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`general -- I can say in general, yes, but
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`specifically, I would really like to have a chance
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`to look at this.
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`BY MR. GARDNER:
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` Q Do you recall anything from that deposition 09:30:55
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`that you think you answered dishonestly or
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`incorrectly?
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` A God, I wish my memory were that good.
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` There are many patents at issue.
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` MR. ABRAMSON: Objection. 09:31:11
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` THE DEPONENT: I'm sorry. Go ahead.
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`BY MR. GARDNER:
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` Q So I'll just ask again.
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` Do you recall anything from that deposition
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`that you think you answered dishonestly or 09:31:18
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`incorrectly?
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` A I do not recall anything that was dishonest
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`or incorrect.
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` Q Let's go to Exhibit 1102. Can you open that
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`document? 09:31:31
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` A All right. One second. I'm sorry. It just
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`takes it a second to open. Okay. I'm on 1102.
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` Q And is this a copy of your deposition
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`transcript from August 3rd, 2023?
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` A It appears to be. 09:31:58
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` Q And during that deposition, did you answer
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`questions honestly, Mr. Hoarty?
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` MR. ABRAMSON: I'm going to object again.
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` This -- I believe this transcript is signed,
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`and these questions are -- these questions are 09:32:16
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`beyond the scope of direct.
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` MR. GARDNER: Mr. Abramson, you are limited
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`to objecting to form.
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` MR. ABRAMSON: I'm not limited to objection
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`to form. Go back and read the trial practice guide. 09:32:31
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`My objection was proper, and I stand on the
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`objection.
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`BY MR. GARDNER:
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` Q Mr. Hoarty, did you answer questions honestly
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`during your August 3rd, 2023 deposition? 09:32:46
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` A Yes.
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` Q And do you stand by the testimony you
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`provided during your August 3rd, 2023 deposition?
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` MR. ABRAMSON: Objection. It's beyond the
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`scope of this direct. 09:32:59
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` THE DEPONENT: All I can say is that on
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`occasion, I was perhaps misunderstood a question. I
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`might not have answered as clearly as I could have
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`or fully understand -- understood a question.
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` So without reviewing -- without a specific 09:33:13
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`question, I can say, in general, I did my best.
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`There were things I didn't fully understand that
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`perhaps I could have answered better.
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`BY MR. GARDNER:
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` Q Are you aware -- are you aware of any 09:33:29
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`examples of that?
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` A Again, I truly wish my memory were that
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`articulate, but without -- without looking at the
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`document or being referenced to a particular
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`question, that would not -- I don't have a specific 09:33:43
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`example that I could provide.
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` Q Do you have the '594 patent available,
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`Mr. Hoarty?
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` A I do.
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` Q Can you open that? 09:33:57
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` A I will. Give me one second.
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` It's open.
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` Q Can you go to Claim 1 of the '594 patent?
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` A Sure.
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` Okay. I'm there. 09:34:23
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` Q Actually, before I do this, do you also have
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`the '636 and '824 patents open?
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` A I have '834 open. I can get '636. I have
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`two of the three. But give me one second.
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` Okay. They are open. 09:35:13
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` Q I want to start with Claim 1 of the '594
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`patent.
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` Are you there?
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` A I am.
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` Q And Claim 1 of the '594 patent recites a 09:35:21
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`method for operating a media player to receive and
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`play an audio or video program.
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` Do you see that?
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` A I do.
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` Q Now, I want you to move to Claim 1 of the 09:35:33
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`'636 patent.
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` A Okay.
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` Q In Claim 1 -- sorry.
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` Are you there?
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` A Almost. I am there. 09:35:50
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` Q Claim 1 of the '636 patent recites a method
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`for distributing a live audio or video program.
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` Do you see that?
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` A I do.
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` Q And can you go to Claim 1 of the '824 patent? 09:36:01
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` A One second.
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` Let me just adjust something here so it's a
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`little bit easier for me to dance around here. I'm
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`sorry. I thought I had that lined up. My
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`apologies. 09:36:39
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` Okay. I have it.
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` Q Claim 1 of the '824 patent recites (as read):
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` "A method for distributing over the
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` Internet from a server system to one
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` or more user systems a prerecorded 09:36:51
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` audio or video program."
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` Do you see that?
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` A I do.
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` Q So just for the record, the '594, the '636,
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`and the '824 all reference an audio or video program 09:37:10
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`in the preamble, correct?
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` A Correct.
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` Q In your view, Mr. Hoarty, other than the
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`difference between live and prerecorded, does the
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`phrase "audio or video program" in the '594, '636, 09:37:26
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`and '824 patents mean the same thing?
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` MR. ABRAMSON: Object; beyond the scope.
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` THE DEPONENT: On the face of it. It appears
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`that audio and video program would mean the same
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`thing. 09:37:48
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`BY MR. GARDNER:
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` Q Can you go to back to the '594 patent?
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` And I would like you to go to Column 14.
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` A All right. I'm there.
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` Q And in Column 14 at line 56, there's a 09:38:08
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`sentence that reads (as read):
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` "The user computer then continues
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` with additional data requests for the
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` duration of playing the audio/video
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` material." 09:38:26
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` Do you see that?
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` A I do.
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` Q And in your opinion, Mr. Hoarty, these lines
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`would help a person of skill in the art understand
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`the meaning of audio or video program in the claims. 09:38:40
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` Correct?
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` A I would presume so. Yes.
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` Q And you agree, Mr. Hoarty, that when the
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`specification says, quote, for the duration of
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`playing, end quote, that could be only 10 seconds of 09:39:02
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`a 1-minute video, correct?
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` MR. ABRAMSON: Object; beyond the scope of
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`direct.
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` THE DEPONENT: Without any further context,
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`duration is whatever it implies, whatever the user 09:39:20
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`-- as a POSITA, assume it made reference to a user
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`of the system's choice.
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`BY MR. GARDNER:
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` Q And that could be just a portion of the audio
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`or video program, correct? 09:39:43
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` A Yes. As far as I understand human nature,
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`absolutely.
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` MR. ABRAMSON: Object to the form.
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` THE DEPONENT: Sorry.
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`BY MR. GARDNER: 09:39:58
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` Q So you would agree, Mr. Hoarty, that an audio
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`or video program might only refer to a portion of
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`the program, correct?
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` A I believe it could.
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` Q Are you aware that the patent owner has taken 09:40:14
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`the position that an audio or video program refers
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`to the entirety of an audio or video program?
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` A I can see how that could -- that could easily
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`be the case. It's a term that can be used in
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`context. 09:40:40
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` Q But you agree in the context of the claims
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`and in the patent that audio/video program could
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`refer to either a portion of the audio or video
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`program or the entirety of the audio/video program,
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`correct? 09:40:55
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` MR. ABRAMSON: Object to the form.
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` THE DEPONENT: If it's in reference to a
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`claim and the intent of the claim, I would not have
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`an opinion.
`
`/// 09:41:03
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`BY MR. GARDNER:
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` Q But at least the portion of the specification
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`that we looked at in the '594 patent in Column 14,
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`lines 56 through 58, you would understand that to
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`reference that the audio or video program could be 09:41:27
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`just a portion of the program or the entirety of the
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`program, correct?
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` MR. ABRAMSON: Object to form.
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` THE DEPONENT: In the context of the
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`specification, it would -- as a POSITA, I would read 09:41:43
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`that as the duration that the user was viewing the
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`program.
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`BY MR. GARDNER:
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` Q And we agree that could be just a portion of
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`the program, correct? 09:41:56
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` MR. ABRAMSON: Object -- just object to the
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`form. He answer -- he answered the question.
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`BY MR. GARDNER:
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` Q I'm not sure. There's no answer on the
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`record. So -- 09:42:06
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` MR. ABRAMSON: He answered the previous
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`question, and you asked it again. He answered
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`already.
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` MR. GARDNER: I'll ask the question again.
`
`/// 09:42:17
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`BY MR. GARDNER:
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` Q Can we agree that the duration that the user
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`was viewing the program could just be a portion of a
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`program, correct?
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` MR. ABRAMSON: Object to the form. 09:42:26
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` THE DEPONENT: In the -- in the context of
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`the specification, I would read this it would be as
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`the user computer is playing for the duration that
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`the user wishes the program to play.
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`BY MR. GARDNER: 09:42:42
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` Q I just want to be clear, Mr. Hoarty, that
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`that could just be a portion of the program,
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`correct?
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` A Sure. I watched the beginning of Top Gun
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`last night. But my wife is tired of me watching it 09:42:53
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`for the 50th time, so I only watched the first
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`5 minutes. So yes, it could be whatever -- whatever
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`the user chooses.
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` Q I want to go back to Claim 1 of the '594
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`patent. 09:43:12
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` A Okay.
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` I'm there.
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` Q You see, I guess it's in the second
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`limitation, where it recites "receiving each" and
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`starts there. 09:43:35
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