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` UNITED STATES DISTRICT COURT
` WESTERN DISTRICT OF TEXAS
` WACO DIVISION
`OZMO LICENSING, LLC
`) Docket No. WA 22-CA-642 ADA
` )
`vs.
` ) Waco, Texas
` )
`DELL TECHNOLOGIES, INC., )
`) June 28, 2023
`DELL, INC.
` TRANSCRIPT OF MARKMAN HEARING VIA VIDEOCONFERENCE
` BEFORE THE HONORABLE ALAN D. ALBRIGHT
`APPEARANCES:
`For the Plaintiff:
`
`Mr. James C. Hall
`Prince Lobel Tye, LLP
`One International Place,
`Suite 3700
`Boston, Massachusetts 02110
`Mr. Karl A. Rupp
`Sorey & Hoover, LLP
`One Liberty Place
`100 North 6th Street, Suite 502
`Waco, Texas 76701
`Mr. Chris M. Katsantonis
`DLA Piper, LLP
`444 West Lake Street, Suite 900
`Philadelphia, Pennsylvania 19103
`Ms. Erin P. Gibson
`DLA Piper, LLP
`4365 Executive Drive, Suite 1100
`San Diego, California 92121
`Mr. Brian K. Erickson
`Mr. John M. Guaragna
`DLA Piper, LLP
`303 Colorado Street, Suite 3000
`Austin, Texas 78701
`Ms. Lily Iva Reznik, CRR, RMR
`501 West 5th Street, Suite 4153
`Austin, Texas 78701
`Proceedings reported by computerized stenography,
`transcript produced by computer-aided transcription.
`
`For the Defendant:
`
`Court Reporter:
`
`
`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
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`DELL
`EXHIBIT 1024 - PAGE 1
`
`
`
`
`
`
`
` UNITED STATES DISTRICT COURT
` WESTERN DISTRICT OF TEXAS
` WACO DIVISION
`OZMO LICENSING, LLC
`) Docket No. WA 22-CA-642 ADA
` )
`vs.
` ) Waco, Texas
` )
`DELL TECHNOLOGIES, INC., )
`) June 28, 2023
`DELL, INC.
` TRANSCRIPT OF MARKMAN HEARING VIA VIDEOCONFERENCE
` BEFORE THE HONORABLE ALAN D. ALBRIGHT
`APPEARANCES:
`For the Plaintiff:
`
`Mr. James C. Hall
`Prince Lobel Tye, LLP
`One International Place,
`Suite 3700
`Boston, Massachusetts 02110
`Mr. Karl A. Rupp
`Sorey & Hoover, LLP
`One Liberty Place
`100 North 6th Street, Suite 502
`Waco, Texas 76701
`Mr. Chris M. Katsantonis
`DLA Piper, LLP
`444 West Lake Street, Suite 900
`Philadelphia, Pennsylvania 19103
`Ms. Erin P. Gibson
`DLA Piper, LLP
`4365 Executive Drive, Suite 1100
`San Diego, California 92121
`Mr. Brian K. Erickson
`Mr. John M. Guaragna
`DLA Piper, LLP
`303 Colorado Street, Suite 3000
`Austin, Texas 78701
`Ms. Lily Iva Reznik, CRR, RMR
`501 West 5th Street, Suite 4153
`Austin, Texas 78701
`Proceedings reported by computerized stenography,
`transcript produced by computer-aided transcription.
`
`For the Defendant:
`
`Court Reporter:
`
`
`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
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`DELL
`EXHIBIT 1024 - PAGE 1
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`THE COURT: Okeydokey. I am ready to move
`forward. Give me one quick second. Okay. I'll hear from
`Dell on this.
`MR. GUARAGNA: Good afternoon, your Honor.
`It's John Guaragna from DLA Piper for Dell. With
`me on the line from DLA are Erin Gibson --
`THE COURT: Okay. Go ahead. Jen, have you
`called the case?
`THE CLERK: No, sir.
`THE COURT: If you'll go ahead and call the case
`and I'll have Mr. Guaragna finish, please.
`THE CLERK: A civil action in Case 6:22-CV-642,
`Ozmo Licensing, LLC vs. Dell Technologies, Incorporated,
`Et Al. Case called for a Markman hearing.
`MR. GUARAGNA: Good afternoon, your Honor.
`John Guaragna from Dell. John Guaragna from DLA
`Piper for Dell. With me, I've got Erin Gibson also from
`DLA Piper.
`MS. GIBSON: Good afternoon.
`THE COURT: Good afternoon.
`MR. GUARAGNA: Also Brian Erickson from DLA, who
`will be handling part of the argument, your Honor.
`MR. ERICKSON: Good afternoon.
`MR. GUARAGNA: And I've got Chris Katsantonis,
`who is a junior associate here at DLA Piper, and he's
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 2
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`3
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`going to be having the privilege of making his first
`Markman argument before your Honor this afternoon. Also
`with us, your Honor, from Dell are Dave Kuznick and Bailey
`Watkins, inhouse counsel, and we're ready to proceed.
`THE COURT: I think Mr. Erickson has sort of a --
`almost feel like a -- I feel like it's the second coming
`with the way the light is emanating from behind him.
`Maybe there will be a revelation by the end of all this.
`MR. ERICKSON: It's the proper reflection, your
`Honor, that bothers me.
`THE COURT: So the first claim term "wireless
`local area network" and that's a claim term I'm sure has
`never been discussed in the history of patent litigation.
`And so, I will hear from Dell.
`MR. ERICKSON: Thank you, your Honor. If I may
`share our screen to display our slides.
`THE COURT: Sure.
`MR. ERICKSON: Thank you.
`Your Honor, defendants' slide 3 provides the
`constructions related to both the wireless local area
`network and wireless personal area network terms as well
`as some fine-tuning proposals from Dell. Now, the parties
`briefed these terms together because the key dispute under
`02 Micro is the difference between them and just when your
`Honor directed us to address the first term, if may I,
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 3
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`4
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`because this is how they were briefed, if it's okay if we
`address them together in this presentation, as well.
`THE COURT: Sure.
`MR. ERICKSON: Okay. Thank you, your Honor.
`So defendants propose that these terms be
`construed to include the numerical coverage ranges that
`are found in the definitions in the intrinsic record and
`the ordinary meaning of these terms. The Court's
`preliminary constructions that are shown here in the
`middle with Ozmo's proposals do not include the numerical
`ranges proposed by Dell. The Court did preliminarily
`construe wireless personal area network as a short-range
`wireless network. But the Court did not construe wireless
`local area network and the lack of a construction leaves
`unresolved the key dispute between the parties.
`Specifically, whether these networks have different
`coverage ranges.
`Now, based on the briefing and all of the
`evidence, including the declaration of Ozmo's own experts,
`which we will discuss in a moment, it appears to be
`undisputed that a wireless local area network is a
`longer-range wireless network relative to a wireless
`personal area network. Thus, while Dell still contends
`that the numerical ranges should be used in the Court's
`construction, Dell has proposed a fine-tuning to the
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 4
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`5
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`Court's preliminary construction of local area network to
`make clear that it is a longer-range wireless network.
`There's a second proposed tuning on slide 3
`related to the personal area network term, which is to
`delete the phrase "usable to connect peripherals to
`devices in close proximity." I'll circle back to address
`that one at the end of my remarks.
`Moving to slide 4, your Honor, this illustrates
`figure 1 from the 814 patent. There are six patents
`asserted in this litigation. They all share a common
`specification so the parties cite only to the 814 patent,
`but you should have the understanding that this is common
`to all six of the patents-in-suit.
`Now, figure 1 is addressing the background of the
`invention and in the background, they explain there are
`many different wireless networks known in the art.
`They're all standardized. You see the standards on the
`left here. And they note that they can be grouped based
`on targeted range. They explain that personal area
`network is the shortest. It can go up to 10 meters, which
`is 30 feet. Wireless local area network can go up to a
`hundred meters, 300 feet. And then, you have metropolitan
`area and wide area that can be measured in kilometers.
`So the industry created these terms solely to
`describe the different size areas covered by these
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 5
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`6
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`different types of networks. You can see it in the name
`itself. They're all wireless area networks. Wide being
`the largest. Metropolitan being the second largest, I
`guess I would say. Local being a medium size network and
`personal being very small. And the differences are huge,
`your Honor. The two are focused on for purposes of this
`case are the local area and personal area. This figure,
`of course, is not to scale. As you can see, the local
`area is 10 times greater in coverage range than the
`personal area network, so this is not a small difference.
`Area, of course, is the square of the range, so
`it's actually a hundred times larger area, all right? So
`ten times larger coverage range. A hundred times larger
`area. So that's why the industry uses different terms to
`describe these different -- very different types of areas.
`Moving to slide 5, your Honor, these are excerpts from
`what the parties refer to as Vleugels I. This is another
`application to the same inventors that's incorporated by
`reference in its entirety into the common specification.
`And the parties rely on Vleugels I for various aspects of
`claim construction.
`What you see here on slide 5 on the left, we have
`reproduced paragraph 7 and this introduces a concept that
`wireless communication systems can be categorized based on
`coverage range. And you'll notice in light blue and, your
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 6
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`7
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`Honor, we've attempted to highlight all of the wireless
`local area terms in light blue and information relevant to
`the local area network in light blue and personal area
`network in yellow. You'll see they first introduced the
`local area network and they say it has a typical coverage
`range on the order of 300 feet. Then they go on to
`describe other aspects that can also be part of the local
`area network.
`The next paragraph, paragraph 8 goes to the next
`type of network, next category, which is a personal area
`network and they say it's a short-ranged wireless network
`that's consistent with the Court's preliminary
`construction. But they do clarify that when they refer to
`short range, they mean a typical coverage range on the
`order of 30 feet. So defendants contend that this is an
`express definition, but it's also tracking precisely the
`ordinary meanings of these terms. These terms were
`created by the industry to describe categories of networks
`of these sizes.
`So this reenforces, your Honor, that defendants'
`numerical limitations are correct and should be adopted in
`the Court's construction; but failing that, defendants
`propose fine-tuning. We should all be able to agree even
`if we're not going to agree on the numerical limits that a
`wireless local area network is a category of network that
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 7
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`has a longer range than the personal area network.
`Moving to slide 6, this shows the next paragraph
`of Vleugels I, which is paragraph 9.
`THE COURT: Could you hold on? I'll be right
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`back.
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`MR. ERICKSON: Yes, your Honor.
`THE COURT: Okay. Would you put back up your
`current proposed constructions? Now, when you say gotta
`be a WLAN, I think a concern I have about that is maybe
`just grammatical, which is, I think what you're saying is
`plain and ordinary meaning, which is a longer-range
`wireless network than a WPAN is what you're saying.
`MR. ERICKSON: Yes, your Honor.
`THE COURT: Okay. Got it. And I'm not sure why
`we're having this fight in the sense that -- I'm not sure
`why you want me to say this because it's all right but I
`think it's correct clearly that the one is larger than the
`other. I'm not sure why we're having this fight. There
`must be something that's going on here that I'm not
`following because I can't imagine -- I cannot imagine an
`expert who's dealing with either of these claim terms
`having a problem or not -- number one, not understanding
`what they both mean and the other is not agreeing that one
`is longer range than the other.
`MR. ERICKSON: Your Honor, we proposed this
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 8
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`fine-tuning to Ozmo this morning. They did not agree at
`that time. After our call, they sent us an e-mail saying
`they would not agree to this fine-tuning. So we'll just
`have to -- they didn't explain why they wouldn't. We'll
`just have to wait to see their presentation today.
`THE COURT: Let me hear from -- who's going to
`argue for the plaintiff?
`MR. RUPP: Good afternoon, your Honor.
`Karl Rupp. Let me introduce who is going to
`speak today. I'll be speaking to the second term. Jim
`Hall from Prince Lobel will speak to this particular term,
`your Honor. And also on the call are some other lawyers
`from Prince Lobel, as well as our client, Chris Dubuc.
`THE COURT: Mr. Hall, what is the fight here?
`I'm not sure I'm following what the fight is.
`MR. HALL: Well, your Honor, it seems from the
`beginning that Dell really wanted to import these
`numerical limitations into the claim and how they're --
`THE COURT: Well, they're not going to be
`numerical. I'm not going to impose numeric limitations.
`But there's no question that there is a difference between
`the two and that one of the differences is in -- if I walk
`out of this room with my EarPods on, they're going to stop
`working because they're Bluetooth, and if I walk out of
`here with my phone, I'm not. So I'm not sure what the
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 9
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`fight is over here.
`MR. HALL: There's no fight over the difference
`between the two networks. Our position was during claim
`construction that WLAN, or wireless local area network, is
`readily amenable to its plain and ordinary meaning. And
`we adopted your Honor's construction of PAN from the Acer
`case in which you construed just personal area network as
`a short-range wireless network usable to connect
`peripherals to devices in close proximity.
`Our position is that that definition of WPAN
`alone juxtaposes the two networks to show that they're
`different.
`THE COURT: Okay. Let me go back to Dell.
`Again, I can't understand what the fight is going to be
`here when your -- I don't understand what the fight's
`going to be between the two parties when you're doing your
`infringement analysis with these two words. Maybe you can
`help me out here. I mean, the plain and ordinary meaning
`to me is -- even I as a dog watching a television level
`technical person is, you know, that WLAN is a larger --
`even though it's a local area network, it's broader than a
`WPAN and I'm not sure why I need to construe it.
`MR. ERICKSON: There is a dispute, your Honor,
`related to, I think, infringement. We don't have
`something like validity contentions yet, so we don't know
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 10
`
`
`
`11
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`what Ozmo will argue with respect to the prior art. But
`we do know from at least some of the networks that's being
`accused on the infringement side, they have identical
`ranges. So in other words, some of the accused networks,
`they'll say the wireless local area network is a 300-foot
`range network and the personal area network is also a
`300-foot range network. So they do --
`THE COURT: I have a hard time believing that an
`engineer would say that about -- I'm not for sure I'm
`pronouncing it right, the WPAN or the W -- I don't know
`how they would say that. I don't know how they would say
`that they have the same range. That's what I'm missing
`here.
`
`MR. ERICKSON: We don't have an expert report
`yet, your Honor, but we do know that Ozmo as a party has
`contended that Wi-Fi is a local area network, which I
`don't think anyone would dispute, but they've also accused
`Wi-Fi direct, which is a type of Wi-Fi, as the exact same
`range as Wi-Fi. It's Wi-Fi direct is the personal area
`network. So that accusation is out there by Ozmo, the
`party. We don't know how they're going to back that up,
`but that shows that the parties do dispute whether
`same-size networks can practice these two limitations.
`THE COURT: Okay. I'll be back in a second.
`Would you put up that -- will you put up your
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 11
`
`
`
`12
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`construction one more time? Dell's construction one more
`time. The Court is going to go with plain and ordinary
`meaning for WLAN. Plain and ordinary meaning, which is a
`longer-range wireless network than WPAN. That's going to
`be the construction for WLAN. I am not going to modify
`the construction for WPAN that I've given in the past.
`So let's move on to the next claim term, which I
`guess we've dealt with here. And then, we have, if I'm
`correct, "overlay protocol" and I look forward to hearing
`the argument on that.
`MR. KATSANTONIS: Good afternoon, your Honor.
`Chris Katsantonis with Dell. I will be briefly
`addressing the Court's preliminary construction for the
`overlay protocol term. But first, before I get started, I
`would like to take a moment to thank your Honor for the
`opportunity to be part of this Markman hearing today as
`this is not only my first Markman hearing but also the
`first time presenting before this court. So thank you,
`your Honor.
`THE COURT: Well, you should have your lawyers
`take you out for a cocktail after this to celebrate.
`MR. KATSANTONIS: I'll be sure to bring that up
`with them, your Honor. Thank you.
`So jumping in, your Honor, we respectfully
`request this court to modify its preliminary construction
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 12
`
`
`
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`for the overlay protocol term in view of Ozmo's sur-reply
`briefing. I'd like to move to slide 15 where we have
`Ozmo's proposed construction which we understand has been
`adopted by the Court as its preliminary construction.
`Now, the only part of the construction that we disagree
`with here is the portion that's been highlighted or
`underlined in red. Excuse me. And this underlined
`portion is the inclusion of this concept that the overlay
`protocol has commonalities with a first protocol to reduce
`interference such that the first and second networks can
`coexist.
`Now, the reason why we disagree with the
`inclusion of this language, your Honor, is because it
`improperly reads in a limitation into the claims.
`Specifically, for taking a look at Ozmo's sur-reply at
`page 6, Ozmo concedes, acknowledges that there are many
`parts in the intrinsic record where the inventors further
`elaborated on various aspects of the overlay protocol,
`where they described various different embodiments related
`to this overlay protocol.
`And this concept of reducing interference for
`coexistence purposes as a product of using common aspects
`of between a first and second network, well, that's simply
`just one of the very many embodiments that is described
`within the intrinsic record. And throughout our claim
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 13
`
`
`
`14
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`construction briefing, your Honor, we identify these
`various different embodiments. And Ozmo without any
`cognizant legal basis has turned around and said no. This
`is the embodiment that's going to be imported into the
`limitation -- into the construction for overlay protocol,
`excuse me.
`But, your Honor --
`THE COURT: Let me ask you.
`MR. KATSANTONIS: Yes.
`THE COURT: I'm sorry. If I could ask a
`question. So as I understand your argument, you are not
`saying that overlay protocol, the claim term, is not a
`protocol governing a second network which protocol has
`aspects in common with a first network protocol to reduce
`interference such that the second and first networks can
`coexist. You're saying that it can do more than -- it
`does more than just being there to reduce interference
`such that the second and first networks can coexist. So
`this is unfairly limiting.
`MR. KATSANTONIS: Yes, your Honor. That's
`exactly it.
`THE COURT: Okay. So let me ask -- I'm sorry.
`You can continue and then, I'll go to the other side.
`Please.
`
`MR. KATSANTONIS: Yes, your Honor.
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 14
`
`
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`So this construction that Ozmo has proposed, they
`have not contended that this is the plain and ordinary
`meaning of an overlay protocol. It's not. It's not the
`definition of an overlay protocol. And there's also no
`disclaimer warranting the importation of this embodiment
`into the claims much less the exclusion of certain
`embodiments that are contemplated by the intrinsic record.
`And excluding an embodiment is exactly what would
`happen, your Honor, under the Court's current preliminary
`construction. Specifically, in Vleugels I, as my
`colleague, Mr. Erickson, explained earlier, is part of the
`intrinsic record. Vleugels I at paragraph 90 discusses
`that interference problems between two networks -- network
`protocols, rather, can be addressed by using different
`frequency bands for each of the network protocols. So in
`that situation, your Honor, it is not the commonalities
`between a first network and a second network that reduces
`interference such that those first and second networks can
`coexist. It's actually the differences between the two
`network protocols that facilitates the reduction in
`interference and allows those first and second networks to
`coexist.
`
`And therefore, your Honor, we would propose that
`the Court delete the portion here that we have underlined
`in red from its preliminary construction as that would not
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 15
`
`
`
`16
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`improperly -- properly exclude any of the disclosed
`embodiments in the intrinsic record.
`THE COURT: Okay. I'll be back in just one
`second. I'm sorry, could you put that slide back up.
`Thanks. I'll be right back.
`Okay. If we could go back on the record with I
`thought -- do my best, Katsantonis? Did I get close?
`MR. KATSANTONIS: Katsantonis.
`THE COURT: Katsantonis. I thought you did a
`very good job, but I'm going to maintain the Court's
`preliminary construction. And that was all I had down
`that we needed to argue unless I'm missing something.
`Is there anything else we need to take up?
`MR. GUARAGNA: No, your Honor.
`MR. RUPP: Not from plaintiff either, your Honor.
`THE COURT: Stay cool out there. Take care.
`Have a good day.
`MR. RUPP: Thank you, Judge.
`(Proceedings concluded.)
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`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`DELL
`EXHIBIT 1024 - PAGE 16
`
`
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`17
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`* * * * * *
`
`UNITED STATES DISTRICT COURT )
`WESTERN DISTRICT OF TEXAS
`)
`
`I, LILY I. REZNIK, Certified Realtime Reporter,
`Registered Merit Reporter, in my capacity as Official
`Court Reporter of the United States District Court,
`Western District of Texas, do certify that the foregoing
`is a correct transcript from the record of proceedings in
`the above-entitled matter.
`I certify that the transcript fees and format comply
`with those prescribed by the Court and Judicial Conference
`of the United States.
`WITNESS MY OFFICIAL HAND this the 5th day of July,
`2023.
`
`
`
`
`
`
`
` 4 4 8 1
`
`LILY I. REZNIK, OFFICIAL COURT REPORTER
`U.S. DISTRICT COURT, WESTERN DISTRICT OF TEXAS (AUSTIN)
`
`~~~~~~~~~~~~~~~~~~~~~~~
`L I L Y I .
` REZNIK,
` CRR,
` RMR
`O f f i c i a l C o u r t R e p o r t e r
`U n i t e d S t a t e s D i s t r i c t C o u r t
`A u s t i n D i v i s i o n
`5 0 1 W e s t 5 t h S t r e e t ,
`S u i t e 4 1 5 3
`
`
`
`
`
`
`
`
`
`A u s t i n ,
` T e x a s 7 8 7 0 1
`( 5 1 2 ) 3 9 1 - 8 7 9 2
`S O T C e r t i f i c a t i o n N o .
`E x p i r e s :
` 1 - 3 1 - 2 5
`
`
`
`
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`DELL
`EXHIBIT 1024 - PAGE 17
`
`
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