UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
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`Page 1
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`_________________________
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`PROXENSE, LLC, )
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`Plaintiff, )
`)
` vs. ) Civil Action No.
`) 6:23-cv-320
`GOOGLE LLC and GOOGLE )
`PAYMENT CORP. )
`)
`Defendants. )
`_________________________)
`
`ZOOM VIDEOTAPED DEPOSITION OF AVIEL RUBIN
`Key West, Florida
`Monday, December 18, 2023
`Volume I
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`Reported by:
`LORI M. BARKLEY
`CSR No. 6426
`Job No. SF 6357374
`PAGES 1 - 66
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`GOOGLE EXHIBIT 1019
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`FOR THE WESTERN DISTRICT OF TEXAS
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`Page 1
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`_________________________
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`PROXENSE, LLC, )
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`Plaintiff, )
`)
` vs. ) Civil Action No.
`) 6:23-cv-320
`GOOGLE LLC and GOOGLE )
`PAYMENT CORP. )
`)
`Defendants. )
`_________________________)
`
`ZOOM VIDEOTAPED DEPOSITION OF AVIEL RUBIN
`Key West, Florida
`Monday, December 18, 2023
`Volume I
`
`Reported by:
`LORI M. BARKLEY
`CSR No. 6426
`Job No. SF 6357374
`PAGES 1 - 66
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`GOOGLE EXHIBIT 1019
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` UNITED STATES DISTRICT COURT
` FOR THE WESTERN DISTRICT OF TEXAS
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`Page 2
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`_________________________
` )
`PROXENSE, LLC, )
` )
` Plaintiff, )
` )
` vs. ) Civil Action No.
` ) 6:23-cv-320
`GOOGLE LLC and GOOGLE )
`PAYMENT CORP. )
` )
` Defendants. )
`_________________________)
`
` Zoom Videotaped deposition of Aviel Rubin,
`Volume I, taken on behalf of DEFENDANTS, at Key West,
`Florida, beginning at 8:03 a.m. and ending at 9:44
`a.m. on Monday, December 18, 2023, before LORI M.
`BARKLEY, Certified Shorthand Reporter No. 6426.
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`APPEARANCES:
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`SUSMAN GODFREY LLP
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`BY: Bryce Barcelo
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`Attorney at Law
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`1000 Louisiana Street, Suite 5100
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`Houston, TX 77002
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`713-651-9366
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`BBarcelo@susmangodfrey.com
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`QUINN EMANUEL URQUHART & SULLIVAN, LLP
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`BY: John T. McKee
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`Attorney at Law
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`51 Madison Avenue, 22nd Floor
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`New York, NY 10010
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`212-849-7000
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`Johnmckee@quinnemanuel.com
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`Videographer:
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` JoAnn Yager
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` I N D E X
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`WITNESS
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`AVIEL RUBIN
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` PAGE
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` Examination by Mr. McKee 6
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` EXHIBITS
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`NUMBER DESCRIPTION PAGE
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`Exhibit 1 Rubin Declaration 8
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`Exhibit 2 US Patent Number 8352730 8
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`Exhibit 3 US Patent Number 8886954 8
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`Exhibit 4 US Patent Number 9298905 8
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`Exhibit 5 Exhibit 1 to Rubin Declaration 9
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`Exhibit 6 Exhibit 2 to Rubin Declaration 9
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`Exhibit 7 Exhibit 3 to Rubin Declaration 9
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`Exhibit 8 File History for '730 Patent 54
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` Key West, Florida, Monday, December 18, 2023
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` 8:03 a.m.
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`Page 5
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` VIDEO OPERATOR: Good morning. We are on
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`the record at 8:03 a.m. on December 18th, 2023.
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` Please note that this deposition is being
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`conducted virtually. Quality of the recording
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`depends on the quality of camera and Internet
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`connection of participants.
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` What is seen from the witness and heard on
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`screen is what will be recorded. Audio and video
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`recording will continue to take place unless all
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`parties agree to go off the record.
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` This is media number one of the recorded
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`deposition of Aviel Rubin in the matter of Proxense
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`LLC versus Google LLC and Google Payment Corporation,
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`filed in the United States District Court for the
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`Western District of Texas.
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` This deposition is being conducted remotely
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`using virtual technology.
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` My name is JoAnn Yager representing Veritext
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`Legal Solutions, and I am the videographer. The
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`court reporter is Lori Barkley from the firm Veritext
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`Legal Solutions.
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` May we please have introductions beginning
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`with the --
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` MR. MCKEE: Yep, this is John McKee with
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`Quinn Emanuel, on behalf of Google.
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` MR. BARCELO: And Bryce Barcelo on behalf of
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`plaintiff Proxense.
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` AVIEL RUBIN,
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`having been administered an oath, was examined and
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`testified as follows:
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` EXAMINATION
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`BY MR. MCKEE:
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` Q. Dr. Rubin, just to get a few of the
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`formalities out of the way. You've been deposed
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`before, correct?
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` A. Yes.
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` Q. A number of times?
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` A. Yes.
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` Q. So you know the rules?
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` A. Yes.
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` Q. The only thing I'll reiterate is if you
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`could please make sure to provide verbal answers to
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`questions as opposed to umm-hmms, all right?
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` A. Yes.
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` Q. Okay, so I'm going to try to be efficient
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`because I understand you have a hard stop in a few
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`hours.
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` So let's just jump right in. So this is not
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`your first case representing or working on behalf of
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`Proxense involving these patents; is that right?
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` A. That's correct.
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` Q. And in fact you were Proxense's expert in
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`the Samsung case; is that right?
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` A. Yes.
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` Q. And you authored a report that involved
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`among other things the same '730 patent that you're
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`offering claim construction opinions about today?
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` A. Yes. I didn't know if you were asking a
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`question so...
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` Q. All good.
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` A. Yes.
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` Q. In that case, you opined on both
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`infringement and validity, correct?
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` A. I think so. I'd have to look back to
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`refresh my recollection on that.
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` Q. Do you recall -- did you provide a claim
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`construction declaration in that case?
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` A. I don't remember.
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` Q. All right. You just don't remember one way
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`or the other?
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` A. Right.
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` Q. Okay, so before the deposition started, in
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`the interest of expediency, I premarked a number of
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`exhibits and I'm just going to read those for the
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`record now.
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` You should see them on the Egnyte Exhibit
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`Share platform exhibits 1 through 7.
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` Exhibit 1 is the declaration of Aviel B.
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`Rubin in response to declaration of John Black
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`concerning construction of certain terms in US patent
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`number 8352730.
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` (Exhibit 1 was marked for identification by
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`the court reporter and is attached hereto.)
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` MR. MCGEE: Exhibit 2 is US Patent Number
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`8352730.
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` (Exhibit 2 was marked for identification by
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`the court reporter and is attached hereto.)
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` MR. MCGEE: Exhibit 3 is US Patent Number
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`8886954.
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` (Exhibit 3 was marked for identification by
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`the court reporter and is attached hereto.)
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` MR. MCGEE: Exhibit 4 is US Patent Number
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`9298905.
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` (Exhibit 4 was marked for identification by
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`the court reporter and is attached hereto.)
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`///
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` MR. MCGEE: And then Exhibits 5, 6, and 7
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`are exhibits 1, 2 and 3 to your declaration,
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`respectively.
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` (Exhibit 5 was marked for identification by
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`the court reporter and is attached hereto.)
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` (Exhibit 6 was marked for identification by
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`the court reporter and is attached hereto.)
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` (Exhibit 7 was marked for identification by
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`the court reporter and is attached hereto.)
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`BY MR. MCGEE:
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` Q. Do you see those exhibits?
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` A. Yes.
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` Q. Okay, so let's start by pulling up Exhibit
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`2, the '730 patent. The '730 patent is the first
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`patent in this patent family, correct?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: You're asking if it's the
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`parent patent?
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`BY MR. MCKEE:
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` Q. Yeah, the '730 patent issued from the first
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`non-provisional application filed in its family,
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`right?
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` A. I don't recall that detail. I could see if
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`it's my declaration.
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` Q. Well, if you look at the Exhibit 2, the '730
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`patent, it doesn't say it's a continuation or a
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`continuation in part of a divisional from some other
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`application, right?
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` A. I don't see it say that anywhere on the
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`cover page.
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` Q. And if you were to turn to Exhibit 3 or
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`Exhibit 4, you would see under -- on the cover page,
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`under related US application data that they are a
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`continuation of the application that became the '730
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`patent, right?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: So I'm looking at the covers
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`of those two, and it does say that they're
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`continuations.
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`BY MR. MCKEE:
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` Q. Great. So keep one of those open -- let's
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`keep the '905 opened. And if you could turn to
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`column 4 for me.
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` Let me know when you're there.
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` A. And just to be clear, you're talking about
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`the '905, not the '730.
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` Q. Right, the '905 patent, Exhibit 4.
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` A. Okay.
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` Q. You see the paragraph that in column 4 that
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`begins at line 1 and ends at line 16?
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` A. Yes.
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` Q. You're familiar with that paragraph?
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` A. I've seen it before but I -- yes, I'm
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`familiar with it.
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` Q. And in particular, I'd like to focus on the
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`language beginning about halfway through line 8 that
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`begins at the end of the line.
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` It says, "in one embodiment the biometric
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`100 is integrated into another object or device."
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` Do you see that?
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` A. I do.
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` Q. And continues, "a device having an
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`integrated biometric key 100 is occasionally referred
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`to herein as an integrated device."
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` Do you see that as well?
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` A. I do not.
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` Q. That language -- is that consistent with
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`your opinion as to the plain meaning of integrated
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`device?
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` MR. BARCELO: Objection, form, vague.
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` THE WITNESS: So it's the sentence, "a
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`device."
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` And your question is if that's consistent
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`meaning?
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`BY MR. MCKEE:
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` Q. Yes.
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` A. Yes.
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` Q. And it continues, for example, "in one
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`embodiment the biometric key 100 is integrated into a
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`mobile phone."
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` And then it gives a laundry list of other
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`devices it could be integrated into.
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` Do you see that?
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` A. I see that.
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` Q. That's also consistent with your
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`understanding or opinions regarding the plain meaning
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`of integrated device, correct?
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` MR. BARCELO: Objection, form, vague.
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` THE WITNESS: Are you asking -- 'cause the
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`sentence that you just read.
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` So when you say that is consistent with the
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`plain and ordinary meaning, what are you referring
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`to?
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`///
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`BY MR. MCKEE:
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` Q. Well, it's your opinion, isn't it, that if
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`the biometric key is integrated into a mobile phone,
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`a tablet, a laptop, an MP3 player or mobile gaming
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`device, that device then becomes an integrated
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`device?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: Well, it may have already been
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`an integrated device. But it is still an integrated
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`device -- I don't know that that transforms it from a
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`nonintegrated device to an integrated device.
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`BY MR. MCKEE:
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` Q. And just to be clear, the integrated device
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`is the -- let me ask this differently.
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` Is the integrated device in your opinion
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`that the larger device that multiple components are
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`integrated into? Or is it the individual components
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`that are integrated?
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` MR. BARCELO: Objection, form, vague,
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`compound.
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` THE WITNESS: So can we talk about one of
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`these items specifically?
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`BY MR. MCKEE:
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` Q. Sure. So if we can just take that last
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`sentence and it says, "the biometric key 100 is
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`integrated into a mobile phone."
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` What is the integrated device then? Is it
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`the biometric key or the mobile phone?
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` A. It would be the mobile phone.
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` Q. Because the biometric key is integrated into
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`the mobile phone?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: I'm not sure I understand your
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`question. Are you asking me is a mobile phone an
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`integrated device because it has a biometric key?
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`BY MR. MCKEE:
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` Q. It's alright, we can move on from this. I
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`think you answered my question already.
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` So I want you to look -- we started here at
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`line 8 where it begins, "in one embodiment," and I'd
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`like you to look at the sentence before that that
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`says, "biometric key 100 has a small form factor such
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`that it can be unobtrusively carried by user."
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` Do you see that?
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` MR. BARCELO: Objection, form, misstates
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`evidence.
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` THE WITNESS: Yes.
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`BY MR. MCKEE:
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` Q. All right, if you could turn to Exhibit 2,
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`the '730 patent for me. Just hold that in your mind.
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` And turn to column 3. Let me know you're
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` A. Okay.
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` Q. And do you see that there is a -- line
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`numbers are a little off.
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` But do you so that there is a paragraph
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`beginning with the language, "figure 1 is a
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`schematic" on approximately line 12. And it
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`continues down to about line 20, ending with the same
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`language we just looked at: "Such that it can be
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`unobtrusively carried by a user."
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` MR. BARCELO: Objection, form.
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` THE WITNESS: I see that.
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`BY MR. MCKEE:
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` Q. All right. So the following sentence that
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`we just looked at that reads, "in one embodiment, the
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`biometric key 100 is integrated into another object
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`or device."
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` That's not in the '730 patent, right?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: Just to be clear so I know if
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`I'm searching the whole '730 patent, are you just
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`saying that the sentence that would come after
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`"unobtrusively carried by user in '730" is not the
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`BY MR. MCKEE:
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` Q. Yeah, the sentence that follows
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`"unobtrusively carried by user" in the '905 patent is
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`not there in the '730 patent?
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` A. Anywhere or right after --
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` Q. Anywhere but certainly not right after that
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`sentence.
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` MR. BARCELO: Objection, form.
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` THE WITNESS: Let me, I need to download
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`these. Because I have no way of looking at both of
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`them at the same time.
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` MR. MCKEE: That's fine, download them and
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`put them on the screen next to each other. I think
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`that could be helpful.
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` Q. So, that's column 3 of the '730 patent and
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`column 4 of the '905 patent.
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` Paragraph beginning with, "figure one is a
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`schematic diagram."
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` A. Okay, I've downloaded them on my computer
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`now. Open them.
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` All right. So on the '730, we were in
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`column 4?
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` Q. '730 on column 3 around line 12, '905 you're
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`in column 4 at line one.
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` A. I'm sorry what column in '905. I was in the
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`other one --
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` Q. Column 4, line 1, right at the top.
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` A. Okay, and which sentence am I looking to see
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`if it's not in the '730?
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` Q. The first sentence after "unobtrusively
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`carried by a user?"
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` And in the '905 patent that sentence reads,
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`"in one embodiment, the biometric key 100 is
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`integrated into another object or device."
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` That's not in the '730 patent, right?
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` A. It's not in the paragraph that we're looking
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`at, column 3. But I'm going to have to do a search
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`to see that it's not anywhere in the patent.
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` Q. Please go ahead and confirm that it's not in
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`the patent.
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` A. Okay, I don't see that it is. I did a
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`search.
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` Q. All right. Following the sentence that
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`reads, "a device having an integrated biometric key
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`100 is occasionally referred to herein as an
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`integrated device" is also not in the '730 patent,
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`correct?
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` A. I did a word search in the version you gave
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`me. And I don't see that.
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` Q. And the following sentence that reads (as
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`read):
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` For example, in one embodiment
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` the biometric key 100 is integrated
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` into a mobile phone, e.g., a
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` cellular phone or smart phone,
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` tablet, laptop, MP3 player, mobile
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` gaming device, watch, key fob or
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` other mobile device, thereby making
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` the biometric key 100 unobtrusive to
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` carry."
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` Is also not in the '703 patent?
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` A. So I did a search on the word "unobtrusive"
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`and it wasn't there. So I take it that sentence
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`couldn't be in there.
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` Q. Can you take a look at figure 1 for me?
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` A. Which patent?
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` Q. It's the same figure either way.
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` A. Okay.
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` Q. Does that show an integrated device?
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` A. I see that in the text that describes figure
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`1, it says "it comprises a frame, a scan pad and an
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`LED."
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` So it is made up of other components. And
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`so I would say that's an integrated device.
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` Q. Let's talk for a minute about components:
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`How do you understand that term? What is a
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`component?
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` A. I'm just going to download my report.
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` Q. And I can point you -- just to speed us up,
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`I can point you to -- and you're free to take a look
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`at your whole report.
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` I can point you to paragraph 35 you say (as
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`read):
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` In summary, when the '730 patent
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` was filed, the term integrated
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` device was on commonly used and
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` indicates the integration of
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` components into a larger whole.
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` So I see that opinion. I'm trying to
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`understand what components means here.
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` MR. BARCELO: Objection, form.
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` THE WITNESS: So I am not using the word
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`"component" in any way other than its plain English
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`meaning.
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`BY MR. MCKEE:
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` Q. Can it be software?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: In the discussion that I have
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`in my declaration and in the patent, it's referring
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`to a piece of hardware.
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`BY MR. MCKEE:
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` Q. In the context of the patent, your opinion
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`is that an integrated device is a collection of
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`hardware components?
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` MR. BARCELO: Objection, form.
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` THE WITNESS: It's an integration of
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`hardware components.
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`BY MR. MCKEE:
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` Q. And how small can a component be in order
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`for it to still qualify as a component of an
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`integrated device?
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` Does the single capacitor qualify?
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` MR. BARCELO: Objection, vague, compound,
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`calls for speculation.
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` THE WITNESS: I haven't analyzed or
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`previously given thought to that question. It's not
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`something in my declaration.
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`BY MR. MCKEE:
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` Q. What about a collection of circuit elements
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`like a low-pass or high-pass filter?
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` MR. BARCELO: Objection, form, compound,
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`vague. Calls for speculation.
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` THE WITNESS: I haven't looked at that
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`either.
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` Q. If I were to stick a low-pass or high-pass
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`filter into a radio, is that radio now an integrated
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`device?
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` MR. BARCELO: Objection, form. Calls for
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`speculation. Vague.
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` THE WITNESS: I haven't studied that
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`question.
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`BY MR. MCKEE:
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` Q. Well, you studied the question of what an
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`integrated device is, and you say it has a plain
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`meaning, right?
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` A. Yes.
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` Q. So to a person of skill at the time of this
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`patent, understanding the plain meaning of integrated
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`device, if I stuck a low-pass filter into a radio,
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`would that person of skill consider that to be an
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`integrated device?
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` MR. BARCELO: Objection, form. Vague.
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`Calls for speculation.
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` THE WITNESS: I would want to take a look at
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`the radio, take a look at the high-pass filter and
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`perform an analysis.
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` You're asking me to comment on something
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`that I haven't analyzed.
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`BY MR. MCKEE:
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` Q. What would you need to see in the high-pass
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`filter we're talking about here in order to determine
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`whether it is or is not a component that can be part
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`of an integrated device?
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` MR. BARCELO: Objection, vague. Calls for
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`speculation.
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` THE WITNESS: I haven't thought about that
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`either.
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`BY MR. MCKEE:
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` Q. Have you thought about any question
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`vis-a-vis integrated device other than biometric
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`keys?
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` MR. BARCELO: Objection, form, vague.
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` THE WITNESS: So I previously mentioned that
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`a frame, a scan pad, an LED, can be components.
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`BY MR. MCKEE:
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` Q. You understand that in order to ascertain
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`whether a claim term is definite, that a person of
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`skill in the art has to be able to ascertain its
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`scope with reasonable certainty, right?
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` MR. BARCELO: Objection, calls for a legal
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`conclusion.
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` MR. MCKEE: Not a legal conclusion?
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` THE WITNESS: I'm not a lawyer --
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` MR. BARCELO: Sorry, what was that, counsel?
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` MR. MCKEE: I'm asking for his legal
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`understanding, not a legal conclusion.
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` MR. BARCELO: Okay, well, that wasn't clear
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`in your question. So my objection stands. If you'd
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`like to re-ask, the question go ahead.
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` MR. MCKEE: If you had the Real Time up I
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`said: "Dr. Rubin, do you understand that a person of
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`skill in the art, that definiteness is evaluated from
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`the perspective of a person of skill in the art
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`seeking to ascertain the scope of a claim term."
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` MR. BARCELO: Objection, calls for a legal
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`conclusion.
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` THE WITNESS: So I'm not a lawyer. But my
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`understanding is that -- I would add to that that
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`it's at the time of the invention and that is
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`correct.
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`BY MR. MCKEE:
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` Q. If a person of ordinary skill in the art
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`cannot ascertain the scope of a claim term,
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`"reasonable certainty," the claim term is not
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`definite, correct?
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` MR. BARCELO: Objection, calls for a legal
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`conclusion.
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` THE WITNESS: Again, I'm not a lawyer. But
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`that sounds like the legal standard.
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`BY MR. MCKEE:
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` Q. So we've said that a biometric key in your
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`opinion integrated into a phone is an integrated
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`device, right?
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` A. Are you asking me if the biometric key or
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`the phone is an integrated device?
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` Q. The phone.
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` A. Yes.
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` Q. And a device that comprises a frame, scan
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`pad, and LED is an integrated device, right?
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` MR. BARCELO: Objection, form, compound.
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` THE WITNESS: I would say that a device that
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`is composed of those components is an integrated
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`device.
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`BY MR. MCKEE:
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` Q. What else is an integrated device?
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` MR. BARCELO: Objection, vague, calls for
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`speculation.
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` THE WITNESS: There are many things that are
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`integrated devices. I don't know --
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`BY MR. MCKEE:
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` Q. -- list --
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` A. Phone, biometric key, a smart TV, a tablet.
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` Q. What about on the other side of the coin:
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`What are some things that in your opinion are not
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`integrated devices?
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` A. A book.
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` Q. In the electronics context, are there any
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`examples you can provide me of devices that are not
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`integrated?
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` MR. BARCELO: Objection, vague.
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` THE WITNESS: I would say like a -- a memory
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`chip that is not connected to anything.
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`BY MR. MCKEE:
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` Q. Okay. Just before I move on -- I'm going to
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`talk about the exhibit to your declaration in just a
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`minute.
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` First, I'd just like to confirm it's your
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`opinion that integrated device has the same meaning
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`across the '730, '905, and '954 patents that are
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`marked as Exhibits 2 through 4 to this deposition,
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`correct?
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` MR. BARCELO: Objection, compound.
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` THE WITNESS: So I do address that in
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`paragraph 32. I say that, "furthermore I expect a
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`POSITA to interpret the term integrated device
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`consistently across patents that are derived from the
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`same parent application, which these are."
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`BY MR. MCKEE:
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` Q. And then at the end of that paragraph, you
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`say, "I believe a person of skill in the art would
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`have understood the term integrated device the same
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`way across all three patents," right?
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` A. Right.
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` MR. BARCELO: Objection, misstates the
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`evidence.
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`BY MR. MCKEE:
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` Q. Just trying to establish here, we are saying
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`that -- or you're saying that integrated device,
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`means the same thing across all three patents?
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` A. Yes.
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` Q. All right, can you pull up Exhibit 5 to your
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`deposition for me, please, which is exhibit 1 to your
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`declaration.
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` And let me know when you have that opened.
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` A. Okay.
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` Q. All right, do you recognize this paper?
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` A. Yes.
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` Q. All right. What is it?
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` A. It's a publication in the 1999 IEEE called,
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`A New Circuit Breaker Integrated Device for
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`Protection Applications.
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` Q. What is the integrated device here?
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` MR. BARCELO: Objection, vague.
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` THE WITNESS: At a high level, it's a
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`circuit breaker device.
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`BY MR. MCKEE:
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` Q. So can you turn to figure 2 on page -- well,
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`its IEEE page number is page 316.
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` A. Yes.
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` Q. Is that the integrated device shown there in
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`figure 2, A and B?
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` MR. BARCELO: Objection, compound.
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` THE WITNESS: So that is an illustration
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`from a particular perspective, a cross-section of the
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`integrated device.
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`BY MR. MCKEE:
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` Q. And what's shown on the left in figure 2(a),
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`is that the equivalent electrical circuit for the
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`integrated device, right?
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` A. That's what it says.
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` Q. And shown on the right in figure 2B, that's
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`a schematic cross-section of the integrated device,
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`right?
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` A. Yes.
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` Q. And what figure 2B is showing -- correct me
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`if I'm wrong -- is four different transistors.
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` I'm sorry, three different transistors and a
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`logic gate DZ?
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` A. So I'm looking at the text on page 315, it
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`says "figure 2B shows a four-layered technology
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`design."
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` And then it gives information about some of
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`the components there, like the IGBT1 section, and
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`then and you look for the figure you see an MP
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`section, a DZ section, and an IGBT2 section.
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` Q. If you look at the equivalent electrical
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`circuit figure 2A for IGBT1 -- and it's outlined in
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`dashed box.
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` What is shown there?
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` A. I believe -- and I'm not an electrical
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`engineer so this isn't really in my field.
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` But the way I understood this when I read
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`it, is that it's showing the logic that this device
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`performs, what is like another circuit that could
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`perform the same logic.
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` Q. And the thing that's shown on the left of
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`IGBT1, has the arrow pointing into it, that's a
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`schematic representation of a transistor, isn't it?
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` A. I'm sorry -- oh, in A?
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` Q. In A.
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` A. It's been I think 35 years since I had a
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`hardware course. But I think that's right.
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` Q. So the integrated device in this paper,
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`Exhibit 5, is a collection of circuit elements,
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`correct?
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` A. What I see in figure 2B is a -- several
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`components. I don't know enough of electrical
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`engineering to say whether they're transistors or
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`what the particular hardware pieces look like.
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` But it is four pieces of hardware that are
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`put together into a whole system.
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` Q. I suppose that's fine, that's helpful to
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`understand.
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` Figure 2B in your opinion shows a collection
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`of components that are integrated together; is that
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`fair?
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` A. Yes.
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` Q. We might come back to this but let's move to
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`Exhibit 6 to the deposition, which is exhibit 2 to
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`your declaration.
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` And please let me know when you have that
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`opened.
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` A. Okay.
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` Q. All right. What is this paper?
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` A. This is a publication of the IEEE from 1988.
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`And it's titled, "Seminet Further Advances an
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`Integrated Device/Circuit Simulation For Power
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`Electronics."
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` Q. In the title there, it says, "integrated
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`device/circuit."
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` Do you see that?
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` A. Yes.
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` Q. And it's your understanding that when
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`someone were to -- in common parlance when you're
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`writing if you say something like device/circuit,
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`you're saying those two things are interchangeable,
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`right?
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` A. I don't know that is a hard-and-fast rule.
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` Q. Okay, in this paper what is the integrated
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`device?
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` A. So this paper is not focused on a particular
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`integrated device. It's talking about a simulator
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`that can simulate integrated devices.
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` Q. All right, so you look on the very first
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`page the section called Seminet overview, Seminet.
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` A. Yes.
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` Q. And it says that it's a (as read):
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` Circuit simulation package which
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` incorporates an integral device
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` simulator (IVCALC1) to provide DC
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` operating point and time domain
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` transient analysis of circuits
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` containing up to 50 components.
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` Do you see
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