Transcript of John Richard Black,
`Jr., Ph.D. (IPR2023-00459)
`
`Date: April 3, 2024
`Case: Netskope, Inc. -v- Fortinet, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Netskope Exhibit 1018
`
`
`Jr., Ph.D. (IPR2023-00459)
`
`Date: April 3, 2024
`Case: Netskope, Inc. -v- Fortinet, Inc. (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Netskope Exhibit 1018
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` NETSKOPE, INC.,
` Petitioner,
` vs.
` FORTINET, INC.,
` Patent Owner.
` _________________________
` PTAB Case No. IPR2023-00459
` U.S. Patent No. 10,084,825
`
` DEPOSITION OF JOHN BLACK, JR., Ph.D.
` Wednesday, April 3, 2024
` 11:34 a.m. EST
`
`Job No.: 531921
`Pages: 1 - 94
`Stenographically Reported By:
`Alison C. Webster, CSR-6266, RPR, RMR, CRR, RDR
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`2
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` Deposition of JOHN BLACK, JR., Ph.D., produced as a
`witness at the instance of the Petitioner, and duly sworn,
`was taken in the above-styled and numbered cause on Friday,
`March 22, 2024, from 11:34 a.m. to 2:02 p.m. Eastern Time,
`before Alison C. Webster, RPR, CRR, RMR, RDR, CSR-6266
`(Michigan); License No. 14559 (California); License No.
`084.004953 (Illinois); License No. 23001848 (Washington),
`reported by stenographic method, via videoconference,
`pursuant to the Federal Rules of Civil Procedure and the
`provisions stated on the record or attached hereto.
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`3
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` A P P E A R A N C E S
`
`APPEARING ON BEHALF OF THE PETITIONER
` ANDREW KLEIN, ESQUIRE
` BINGJIE (KAY) LI, ESQUIRE
` Perkins Coie LLP
` 3150 Porter Drive
` Palo Alto, California 94304
` 650.838.4754
` aklein@perkinscoie.com
` bli@perkinscoie.com
`
`APPEARING ON BEHALF OF THE PATENT OWNER
` QUINCY LU, ESQUIRE
` Quinn Emanuel Urquhart & Sullivan, LLP
` 1109 First Avenue
` Suite 210
` Seattle, Washington 98101
` 206.905.7000
` quincylu@quinnemanuel.com
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`4
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` T A B L E OF C O N T E N T S
`
` Witness Page
` JOHN BLACK, JR., Ph.D.
`
` EXAMINATION
` BY MR. KLEIN: 6
` EXAMINATION
` BY MR. LU: 86
` RE-EXAMINATION
` BY MR. KLEIN: 88
` RE-EXAMINATION
` BY MR. LU: 91
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` E X H I B I T I N D E X
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` Exhibit Page
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`(Exhibits not offered.)
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`5
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` DEPOSITION OF JOHN BLACK, JR., Ph.D.
` Wednesday, April 3, 2024
`
` STENOGRAPHER: The attorneys participating
`in this deposition and the witness have verified that
`he is John Black, Jr., Ph.D. In lieu of an oath
`administered in person, the witness will visually
`affirm his testimony in this matter is under penalty
`of perjury.
` The parties and their counsel consent to
`this arrangement and waive any objections to this
`manner of reporting or admissibility of the
`transcript.
` Would counsel please state their appearance
`and any objections to proceeding in this manner,
`starting with scheduling counsel.
` MR. KLEIN: Andrew Klein on behalf of
`petitioner Netskope, Inc., and I have no objection.
` MR. LU: Quincy Lu on behalf of patent
`owner Fortinet. I have no objections.
` STENOGRAPHER: Dr. Black, would you please
`raise your right hand.
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`6
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` Do you swear or affirm the testimony you
` are about to give in this matter will be the truth,
` the whole truth, and nothing but the truth?
` DR. BLACK: I do.
` STENOGRAPHER: Thank you.
` You may proceed.
` MR. KLEIN: Good morning, Dr. Black.
` THE WITNESS: Good morning, Mr. Klein.
` JOHN BLACK, JR., Ph.D.,
` was thereupon called as a witness herein, and after
` having first been duly sworn to testify to the truth,
` the whole truth and nothing but the truth, was
` examined and testified as follows:
` EXAMINATION
`BY MR. KLEIN:
`Q. So we're going to first start talking about the '825
` patent, so I just want to make sure you know which IPR
` we're talking about first.
`A. Thank you for clarifying. That's what I was told to
` expect.
`Q. Yeah. And in your expert report that you submitted in
` connection with the '825 patent, you discuss a few
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`7
`
` different topologies. Correct?
`A. I do.
`Q. And I wanted to go through the topologies you
` discussed to see if we can agree on what those
` topologies are and what they look like. And so I
` wanted to first start with the bus topology which you
` mentioned in your report. What is that?
`A. A bus, in computer lingo, is a backplane or a
` connection line. It is sort of the substrate. And
` then each of the computers or devices or whatever the
` context is, connects to that bus.
` So everything -- you can imagine sort of a
` horizontal line going across the top of a piece of
` paper, and then each device or computer component has
` a single wire connecting to that bus and that
` provides sort of the substrate for each of them to
` intercommunicate.
`Q. And is a bus topology typically a line?
`A. It's often drawn that way. I -- you know, when you
` see it implemented it might actually have some
` corners and curves on a motherboard or the cables
` obviously could be curved when they're laid out.
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`Conducted on April 3, 2024
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`8
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`Q. And are all the devices connected to the bus
` interconnected?
`A. Yeah. They have a pathway to one another, so they
` are interconnected in that sense.
`Q. What do you mean, "a pathway to one another"? You
` mean they can just talk to each other some way?
`A. Right. There is a -- there is a pathway. There is a
` path between every pair of devices via the bus.
`Q. Okay. But so if we have, let's say, a bus, and
` there's three devices, there's one up here, one down
` here, and then one over here, are the two devices on
` the end interconnected?
`A. If I understand you properly, it sounds like the two
` on the ends are both connected to the bus. And so,
` yeah, they could talk to each other via the bus.
`Q. Okay. And you also mentioned a ring topology. Right?
`A. Right.
`Q. What does a ring topology look like?
`A. So typically, there, each computer is connected to
` two others in a ring. So the simplest case would be,
` let's say you have three computers, A, B, and C; A
` connects to B, B connects to C, C connects back to A
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`9
`
` again. So they form sort of this ring diagram, if
` you draw it like that.
`Q. Okay. And then you mentioned a point-to-point
` topology too. Correct?
`A. Yes.
`Q. And what does that look like?
`A. Point-to-point is typically restricted to just two
` computers with a single connection between them;
` there's no complexity, there's no switching, there's
` no multi-computer interconnection. It's as simple as
` you can get. It's two tin cans with a string.
`Q. And when you talk about connections, are you talking
` about physical connections between them or logical
` connections between them?
`A. You can talk about both. Right? So you can say,
` what does the physical connection look like, that
` might actually be tangible and might actually be just
` over-the-air because we have wireless networks as
` well.
` But then also in networking we will talk
` about computers being connected in a logical sense.
` And so networking people usually try to make clear
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`10
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` what the context is that they're describing before
` they start the conversation with words of, like,
` connection, to say, you know, are we in this logical
` domain.
` If you're in the data center with pliers
` and wires and connecting things together, now you're
` talking about physical connections.
`Q. So when you're talking about point-to-point, and
` you're saying there is one connection in this
` topology, is that in context -- in that context, is
` that just a single wire or is that a single logical
` connection or both?
`A. So if you're talking in the physical context,
` point-to-point typically means an actual wire between
` the two things that you can touch, or perhaps a
` wireless connection. But if you're in the logical
` context, a point-to-point topology for a logical
` network could actually go across the world and have
` lots of intermediate hops that are transparent
` because you're thinking about the logical connection
` and not the underlying implementation of the
` connection.
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`11
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`Q. So in that last little bit of testimony we were
` talking about, you have multiple hops but it's a
` single logical connection between two devices. Is
` that still point-to-point?
`A. If that's the only connection that's made. If there
` are no other connections between these two, let's
` say, interfaces, one is talking to the other, the
` other is talking to one, and that's it, then
` logically that is a point-to-point connection, even
` though under the covers it might have a lot of
` complexity to what's going on.
`Q. Okay. So a point-to-point is really just the fact
` that there's two devices communicating directly with
` each other and they're not talking to anybody else or
` there's no third party in the conversation?
` MR. LU: Objection. Vague.
`A. Right. Now, that's a point-to-point connection. I
` wouldn't call that a point-to-point topology unless
` you've actually built a network where that's the only
` connection in the network, but I would say that's a
` point-to-point connection.
`BY MR. KLEIN:
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`12
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`Q. So what was the distinction you are making there
` with -- between a point-to-point connection and a
` point-to-point topology?
`A. So you can have two computers that are connected
` together logically in the way that you described,
` where they talk only to one another. But normally
` that's not a network, that's just a connection across
` a network between two computers.
` But you could build a virtual network that
` has its own address space, that it's logically
` insulated from everything else around it, and you
` could do that just between two computers with a
` single connection, so then you would have a
` point-to-point topology of a network implemented.
` That's less common than what we were talking about
` before. Point-to-point connections are extremely
` common.
`Q. So can you explain that a little bit more about what
` exactly is the point-to-point topology?
`A. Sure. So when you have a network, a network is a set
` of computers, two or more, that have connections
` between them somehow. The "somehow" is called the
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`Conducted on April 3, 2024
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`13
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` topology.
`Q. Uh-huh.
`A. So if you have a network that has only two members,
` two computers, two devices, and a single connection,
` the topology is called point-to-point. That's the
` entirety of your network.
` Now, the simplest case is where you
` physically do this and you have two computers in a
` single wire and that's easy enough that everybody can
` understand it. But you can, these days, build virtual
` networks that are basically simulating that physical
` world in software by pretending that you have this
` single wire between them but you're implementing it
` via software by tunneling, by using encryption, by
` using what's called a VPN.
` You can build a separate software
` simulation of a network that way, and then the
` network, in essence, exists because the computer
` believes it's on a separate network, it behaves as
` though it's on a separate network; it thinks the only
` other computer is the -- is the other computer on the
` other end of this single connection. So you would
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`Conducted on April 3, 2024
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`14
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` have a point-to-point topology of that simulated
` network, even though physically it's not going to look
` like a single wire in that case.
`Q. So can you have multiple logical connections between
` two computers over a single wire?
` MR. LU: Objection. Vague.
`A. So certainly if we're talking about TCP/IP, something
` like a TCP/IP connection, you can have multiple
` logical TCP/IP sessions or connections over the same
` wire between two computers.
`BY MR. KLEIN:
`Q. Now, in that scenario, would that be point-to-point
` connection or point-to-point topology?
` MR. LU: Objection. Form.
`A. It would be multiple point-to-point connections. The
` topology is still up in the air. You can have a
` point-to-point connection between two computers, you
` can have multiple point-to-point connection between
` two computers and the topology could still be
` anything.
` You could do it over the Internet, which
` is this massive, you know, interconnected topology.
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`15
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` You could do it over a single physical
` line point-to-point topology. So saying -- you have
` multiple connections doesn't tell you what the
` underlying topology looks line.
`Q. So if I have two computers and there's a single
` physical wire between them but there are multiple
` TCP/IP sessions between those two computers, would
` that be a point-to-point topology?
` MR. LU: Objection. Incomplete
` hypothetical.
`A. The physical topology would be point-to-point, and
` even though you have -- you can still have multiple
` connections over that single wire.
`BY MR. KLEIN:
`Q. And is that because there's just a single wire going
` between the two computers or a single connection?
` MR. LU: Objection. Vague.
`A. Right. The network topology in your example is
` point-to-point and it doesn't mean you can only have
` a single session occurring over that single
` connection.
`BY MR. KLEIN:
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`16
`
`Q. Have you heard of a mesh topology?
`A. Yes.
`Q. And what is a mesh topology?
`A. A mesh -- it's been a while since I looked. I don't
` know if there's a strict definition out there, but in
` the examples I've seen, a mesh is often a topology
` where, for example, you have a set of end computers,
` and each of them is connected -- every given computer
` is connected to all n-1 other computers. So there's
` a full pairing of connections.
` This doesn't scale very well because you
` have n times n-1 minus over two total connections. So
` you've got a lot of connections as the number of
` elements grows.
` You can also take, let's say, ten computers
` on the top of the picture, ten on the bottom, and each
` one on the top connects to all ten on the bottom. So
` that's fewer connections, but I've seen that called a
` mesh as well.
`Q. Okay. So there's a lot more interconnections between
` the devices in the topology.
` MR. LU: Objection. Vague.
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`17
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`A. It conjures that idea. Right? Like, for example, I
` wouldn't consider two computers and a wire to be a
` mesh. Usually it -- it has this flavor of lots of
` interconnections between number nodes.
`BY MR. KLEIN:
`Q. Have you heard of a star topology?
`A. Yes.
`Q. And what is a star topology?
`A. That's typically a topology where you have some
` central network device, typically a router or a
` switch, and then each member of the network connects
` directly to that central component and it is
` responsible for switching or routing or forwarding
` packets as they come in and need to be forwarded on.
`Q. Have you heard of a tree topology?
`A. Yes.
`Q. And what does a tree topology look like?
`A. In a tree, you typically have a root of the tree.
` And in computer science we draw trees upside-down, so
` the root's usually at the top of the picture. And
` then you have various lines coming down from the root
` to intermediate nodes or leaf nodes, we call them
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`18
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` analogously, like, parts of a tree; so branch nodes,
` leaf nodes. But basically there's a node, it has
` lines coming down, there may be further nodes,
` further lines going down, and so forth. So it sort
` of looks like an upside-down tree.
`Q. And have you heard of a fabric topology?
`A. Yes.
`Q. And what is that?
`A. Well, as I state in my declaration, to me -- well,
` "fabric" in the general sense or do we mean "fabric"
` in the way that it's used in the '825 patent? I
` guess I should ask that.
`Q. Well, let's start with "fabric" in the general sense.
`A. "Fabric," in the general sense, again, conjures this
` idea of sort of lots of connections because it's
` supposed to be analogous to the textile version of
` the word where you've got lots of threads interwoven.
` And so, again, it should be something with many nodes
` and many different paths within those nodes
` interconnecting the nodes.
`Q. Is a -- well, strike that.
` And then what do you mean "fabric" in the
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`19
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` context of the '825 patent?
`A. So in the '825 patent, the fabric is of the so-called
` network security appliances. And there I would say
` that the word "fabric" is used to describe several, I
` would say three or more of these NSAs, these network
` security appliances, that are all interconnected via
` multiple paths.
`Q. Is a tree topology a fabric topology or are they
` completely separate topologies?
` MR. LU: Objection. Vague.
`A. I would say that a tree that has at least three
` network security appliances and has multiple paths
` for things coming in and out of it would be a fabric.
`BY MR. KLEIN:
`Q. What do you mean by "paths coming in and out of it"?
` You mean just that -- the ends of those
` three devices or all three of the devices have a
` connection to each other?
`A. Yeah. So if all three are connected to each other,
` it's not a tree anymore. You can't do that with a
` tree. Right? So the network security appliance tree
` would be, let's say, a root with two children, two
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`20
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` leaf nodes, and as long as it was possible to go
` through, pass through that fabric by coming in, let's
` say, in the root and out one of the leaves, but
` there's another path now, which is in the root and
` out the other leaf, those are two separate paths now.
` So I think it constitutes a fabric in that case.
`Q. Because there's multiple ways in and out of the
` topology? Is that what you're saying?
`A. Right. If we instead draw a tree like this, we say
` root, branch, leaf, and that's it, and then the only
` path through that is traffic has to arrive at the
` root, pass through the branch, and exit the leaf,
` that's a single path. And if that's the only path
` available, then to me that's not a fabric in the
` context of the '825.
`Q. And then going back to the hypothetical you just had,
` you said you had a root, a branch, and a leaf, was
` that right, in a single line?
`A. Correct.
`Q. So what if you have what you just said, so you have
` the root, the branch, and the leaf, but then you add
` another branch connected to the root and it's not
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`21
`
` connected to anything else, is that now a fabric?
` MR. LU: Objection. Vague. Incomplete
` hypothetical.
`A. As long as traffic can pass through different paths.
` So now let's say traffic A goes root, branch, leaf,
` and exits the fabric, and then another, traffic B,
` arrives at the root and now goes to that second
` branch that you added and exits. Now you have an
` interconnected network with three or more nodes that
` has multiple paths because we just described two
` different paths there.
`BY MR. KLEIN:
`Q. But the traffic passing through the fabric is only
` going to go through one pathway. Right?
` MR. LU: Objection. Vague.
`A. For a given example, a given instance of a single
` packet traveling through, it will generally just
` travel through one path. But if that's the only
` option that every single packet has in the future as
` well, then I don't think you have a fabric because
` you just have this, like, bucket brigade linear
` arrangement of nodes.
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`22
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`BY MR. KLEIN:
`Q. So is a fabric its own specific type of topology?
` What I mean -- what I mean by that is, we
` talked about the bus topology and the ring topology
` and point-to-point and mesh, star, and tree
` topologies. Is a fabric topology another type of
` topology like those others, or is there a different
` type of relationship?
` MR. LU: Objection. Vague.
`A. I wouldn't say that it's disjoint. Like we just
` described a way that a tree topology could be a
` fabric, so I wouldn't say it's something that's yet
` again separate from every other example that you
` listed.
`BY MR. KLEIN:
`Q. I didn't follow that. Say it again. So it's
` something different?
`A. I would say it's not something that's disjoint, like
` completely unlike any other topology that you listed
` because we just gave an example where a tree topology
` could constitute a fabric.
`Q. Uh-huh. So I just want to make sure I've got right
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
`
`23
`
` exactly what you're saying.
` So a fabric is another type -- another
` specific type of topology, but it's not exclusive.
` Meaning, you have -- you could only have a fabric
` topology, and that's to the exclusion of all the other
` topologies.
`A. Agree. Correct. Yes.
`Q. Okay. So just to flesh that out a little bit more, so
` if we have three computers in a line, is that a
` fabric?
` MR. LU: Objection. Asked and answered.
`A. It could be --
` MR. LU: And vague. Sorry.
` THE WITNESS: Sorry.
`A. It could be if traffic can enter, let's say, the
` middle node in that line and then go left and out,
` but it could also enter the middle and then go right.
` As long as there are separate paths that the traffic
` can follow, then yes. But if traffic can only enter
` on the left side and go to the second node and the
` third node and exit and that's it, then I wouldn't
` say that's a fabric.
`
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`24
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`BY MR. KLEIN:
`Q. Okay. So the fabric is -- is it fair to say that the
` fabric is about the number of pathways available
` through the topology?
` MR. LU: Objection. Vague.
`A. I mean, I would say that multiple pathways are
` required. I wouldn't say there's a specific number.
`BY MR. KLEIN:
`Q. Yeah.
`A. Multiple pathways.
`Q. So at least two pathways through the topology.
`A. At least two.
`Q. Okay. And so if we take that line of computers and
` then we now put them in a triangle, so we have one at
` the top and then one at the top left and then one at
` the bottom right, is that a fabric?
` MR. LU: Objection. Incomplete
` hypothetical.
`A. It is if traffic can enter, let's say, at the top of
` your picture and exit left, but also it could enter
` and exit right. But if the traffic can only enter on
` the left side -- left leaf node, go to the root and
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`Transcript of John Richard Black, Jr., Ph.D. (IPR2023-00459)
`Conducted on April 3, 2024
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`25
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` go out the right-hand leaf node and that's it, then
` no.
`BY MR. KLEIN:
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