Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 1 of 15 PageID #: 24951
`Case 5:19-cv-00036—RWS Document 447-6 Filed 07/27/20 Page 1 of 15 PageID #: 24951
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`EXHIBIT 5
`EXHIBIT 5
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`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 2 of 15 PageID #: 24952
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`Transcript of the Testimony of Jaccob R. Munford
`
`Date: June 19, 2020
`
`Case: Maxell, Ltd. v. Apple, Inc.
`
`Ace-Federal Reporters, Inc.
`Phone: 202-347-3700
`Fax: 202-737-3638
`Email: info@acefederal.com
`Internet: www.acefederal.com
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`

`

`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 3 of 15 PageID #: 24953
`Case 5:19-cv-00036—RWS Document 447-6 Filed 07/27/20 Page 3 of 15 PageID #: 24953
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`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 4 of 15 PageID #: 24954
`Jaccob R. Munford
`June 19, 2020
`
`Maxell, Ltd. v. Apple, Inc.
`
` IN THE UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
` TEXARKANA DIVISION
`
`- - - - - - - - - - - - - -x
`MAXELL, LTD., )
` Plaintiff, )
` vs. ) Civil Action No.
`APPLE, INC., ) 5:19-cv-00036-RWS
` Defendant. )
` - - - - - - - - - - - - - x
`
` TELEPHONIC DEPOSITION OF JACOB R. MUNFORD
`
` Friday, June 19, 2020
`
`REPORTED BY: SUSAN L. CIMINELLI, CRR, RPR
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`202-347-3700
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`1da22ac4-aaf6-4a65-b933-586eb44450e9
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`Page 1
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`

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`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 5 of 15 PageID #: 24955
`Jaccob R. Munford
`June 19, 2020
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`Page 3
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`Page 5
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`APPEARANCES (continued):
`
`MARK LIANG, ESQ. (Via telephone)
`O'Melveny & Myers
`Two Embarcadero Center
`28th Floor
`San Francisco, California 94111-3823
`(415) 984-8882
`mliang@omm.com
`On behalf of Defendant
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` Q Can you please spell your last name?
` A M-U-N-F-O-R-D.
` Q And can you please spell your first
`name?
` A J-A-C-O-B. 11:01:15
` Q And, Mr. Munford, what is your
`current work address?
` A 305 Fairfax Road, Pittsburgh,
`Pennsylvania, 15221.
` Q And your current home address? 11:01:31
` A 305 Fairfax Road, Pittsburgh,
`Pennsylvania, 15221.
` Q And, Mr. Munford, have you ever been
`deposed before?
` A I have. 11:01:50
` Q Approximately how many times?
` A Three.
` Q And when was the last time you were
`deposed?
` A It would have been in October of last 11:02:02
`year, 2019.
` Q So I'd like to go over some
`deposition ground rules, to kind of refresh
`your memory and keep us all on track.
` A Sure. 11:02:16
`
`2 (Pages 2 to 5)
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`Maxell, Ltd. v. Apple, Inc.
`Page 2
` Deposition of JACOB R. MUNFORD, called for
`examination pursuant to notice of deposition,
`on Friday, June 19, 2020, in Washington, D.C.,
`via telephone at 11:00 a.m. EST, before SUSAN
`L. CIMINELLI, RPR, CRR, and a Notary Public
`within and for the District of Columbia, when
`were present via telephone on behalf of the
`respective parties:
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`LUIZ MIRANDA, ESQ. (Via telephone)
`Mayer Brown
`1999 K Street, N.W.
`Washington, D.C. 20006
`(202) 263-3000
`lmiranda@mayerbrown.com
`On behalf of the Plaintiff
`
` -- continued --
`
`Page 4
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` P R O C E E D I N G S
`Whereupon,
` JACOB R. MUNFORD,
`was called as a witness, and having been duly
`sworn, was examined and testified as follows:
` EXAMINATION BY COUNSEL FOR PLAINTIFF
`BY MR. MIRANDA:
` Q Mr. Munford, good morning.
` A Good morning.
` Q I'm Luiz Miranda of Mayer Brown, on 11:00:20
`behalf of Plaintiff Maxell, Limited.
` A Uh-huh.
` MR. MIRANDA: And will Apple's
`counsel introduce himself?
` THE WITNESS: I'm sorry. Do you mind 11:00:34
`repeating that? I couldn't hear you very well.
` MR. MIRANDA: Would Apple's counsel
`introduce himself?
` MR. LIANG: So I'm Mark Liang,
`M-A-R-K, L-I-A-N-G, of O'Melveny Myers, on 11:00:46
`behalf of Defendant Apple, Inc.
`BY MR. MIRANDA:
` Q Mr. Munford, can you please state
`your name for the record?
` A My name is Jacob Munford. 11:01:02
`
`

`

`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 6 of 15 PageID #: 24956
`Jaccob R. Munford
`June 19, 2020
`
`Maxell, Ltd. v. Apple, Inc.
`Page 6
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`Page 8
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` Q So the court reporter is on the line
`here, taking every word anyone says. And
`specifically to telephonic depositions, she is
`unable to see your mouth, so it's even harder
`for her to understand what you're saying. So I 11:02:31
`ask that you please speak slowly, and you
`please wait until I'm finished asking the
`question, and then you respond. Is that okay?
` A That's okay.
` Q And I'll give your counsel an 11:02:43
`opportunity to object, but if your counsel
`objects, please understand that I'm entitled to
`an answer. Do you understand that?
` A I do.
` Q So we'll be taking breaks 11:02:59
`periodically, but if you need a break, just let
`me know. The only time we can't take a break
`is if the question is pending, or if a line of
`questions are pending. If you do not
`understand any part of a question that I ask 11:03:11
`you, please ask for clarification. If you
`don't ask for clarification, I'm going to
`understand that you do understand the question.
`Is that fair?
` A That is fair. 11:03:21
`
`Page 7
`
` Q And do you have any questions about
`anything I've gone over so far?
` A I do not, no.
` Q You understand that while testifying
`today, not including breaks, you may not access 11:03:31
`or look at any information or materials, other
`than the exhibits in the link that were sent to
`you, and once they have been introduced by me.
`Do you understand that?
` A I'm sorry. Could you maybe clarify? 11:03:43
`I can still look at my own deposition that was
`introduced, correct?
` Q Ones that have been introduced today
`by me, yes.
` A Okay. 11:03:55
` Q And do you understand that you're
`under oath today?
` A Yes, I do.
` Q And is there anything that would
`prevent you from giving truthful and accurate 11:04:02
`testimony?
` A There is not.
` Q Are you under any medication that
`could impair your ability to give truthful and
`accurate testimony today? 11:04:12
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` A No, I'm not.
` Q You understand that when I refer to
`your report, I'm referring to the actual report
`titled Expert Report of Jacob Robert Munford
`Concerning Publication and Public 11:04:28
`Accessibility, dated May 7th, 2020?
` A Correct. That is referring to the
`piece on the Cyberguide, correct?
` Q If it's referring to your full expert
`report that was submitted on May 7th, 2020. 11:04:46
` A Could you clarify that?
` Q Go ahead.
` A I just wanted to verify that the
`declaration I'm looking at is concerning the
`Cyberguide publication, as I filed multiple 11:04:59
`declarations and I want to make sure I'm seeing
`the correct one.
` Q Certainly. So this should be the
`publication, the expert report that was
`submitted on May 7th that's titled Expert 11:05:09
`Report of Jacob Robert Munford Concerning
`Publication and Public Accessibility.
` A Does that document have a Civil
`Action Number on the front?
` Q 5:19-CV-00036-RWS. 11:05:25
`
`Page 9
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` A Then I understand that -- sorry.
`Then I understand that we are looking at the
`same document, yes.
` Q And I will be referring to that as
`your report. 11:05:43
` A Yes.
` Q If I refer to asserted patents, it's
`all patents being asserted against Apple in the
`litigation, you understand that?
` A I don't, no. You'd have to clarify a 11:05:55
`little bit more.
` Q What would help you to clarify?
` A I guess I don't understand the nature
`of your question.
` Q So if I refer to the term asserted 11:06:04
`patents, that's to mean all of the patents that
`are being asserted against Apple in this
`litigation, would you understand that, sir?
` A Yes. Sorry. I must have missed a
`few words. That's a fair point. 11:06:18
` Q Mr. Munford, what's the name of your
`current employer?
` A I do not have a current employer.
` Q Do you have a current job?
` A This is my full time job working 11:06:36
`
`866-928-6509
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`Ace-Federal Reporters, Inc.
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`3 (Pages 6 to 9)
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`

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`Maxell, Ltd. v. Apple, Inc.
`Page 10
`freelance as an expert researcher. I also own
`a small card and board game company.
` Q So you said freelance and researcher.
`What kind of research do you do?
` A I primarily do research regarding 11:06:54
`publications such as academic journals, books,
`mostly related to libraries, but sometimes
`related to web designing, Internet resources.
` Q Who do you do the research for?
` A I had a number of clients, including 11:07:14
`Fish & Richardson, Perkins Coie, Erise IP.
` Q Are all your clients law firms?
` A All of my clients are law firms, yes.
`Just -- I wanted to be sure, but yes.
` Q What is the most recent 11:07:32
`publication -- research publication that you've
`done?
` A Do you mean in preparation for filing
`for a deposition, or a deposition that was
`filed? 11:07:49
` Q In any case, research that you've
`done for litigation?
` A I'm been working this week to contact
`several federal repository libraries in the
`United States to verify their ownership of 11:07:59
`
`Page 12
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` A I have been a professional expert
`witness for three plus years, since October
`2018, I believe. I need to verify on my CV.
` Q And how many cases have you been
`involved in as an expert witness? 11:09:12
` A I would say upwards of 16. I don't
`have an exact number, off the top of my head.
` Q Can you list each case that you've
`been involved in as an expert witness?
` A Could you say that again? 11:09:29
` Q Could you list each case that you've
`been involved in as an expert witness?
` A I cannot list each case that I've
`been involved in as an expert witness, no.
` Q Do you remember the last case? 11:09:39
` A As in cases I'm working on currently?
` Q Including cases you're working on
`currently.
` A I have three active cases right now.
` Q What are those cases? 11:09:51
` A I am working for Fish & Richardson
`and Erise IP, Fish on one case, Erise on two,
`for the most part, just looking for Federal
`Government documents in university libraries.
`I'm not exactly sure the details of the case 11:10:08
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`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 7 of 15 PageID #: 24957
`Jaccob R. Munford
`June 19, 2020
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`specific material. So that's what I did this
`week.
` Q Is it fair to say that the research
`that you do on publications is related to your
`job as an expert witness? 11:08:10
` A Yes.
` Q You also mentioned that you do some
`game development.
` A Uh-huh.
` Q And what percentage of your work is 11:08:21
`expert work versus something else, such as game
`development?
` A Sure. It's 98 percent of my work.
`My game development company was started last
`week and we don't even have a product in the 11:08:33
`stores yet, so -- 99 percent of the work I do
`is research and 100 percent of my income.
` Q That's fine. So would it be fair to
`say that you're a professional expert witness,
`then? 11:08:48
` A That would be fair to say, yes. But
`only for specific topics that I feel
`comfortable.
` Q And how long have you been a
`professional expert witness for? 11:08:55
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`themselves, as I'm usually not privy to that
`information.
` Q How about the other two?
` A The other two would be through Erise
`IP. And I'm in various states of being done, 11:10:22
`because I'm contacting different libraries.
`Again, I don't know much detail about the case.
`Typically in my work I don't get the details of
`the case. I only get which material is being
`worked on. 11:10:39
` Q Do you remember the last case that
`was worked on that's not ongoing right now?
` A It would have been last night,
`although I couldn't give a date on that.
` Q Do you remember what the client was 11:10:51
`for that case last month?
` A Fish & Richardson.
` Q But you don't recall who the party
`was?
` A No. I have several different cases 11:11:03
`with Fish & Richardson. I only always know
`what is involved in the litigation itself. If
`I'm going to be making any definitive
`statements on the record, I don't want to do
`so, when I could easily be getting into the 11:11:15
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`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 8 of 15 PageID #: 24958
`Jaccob R. Munford
`June 19, 2020
`
`Maxell, Ltd. v. Apple, Inc.
`Page 14
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`case.
` Q And how about before last month, the
`last case that you worked on, do you remember
`who the party was?
` A I had cases with Fish & Richardson 11:11:35
`and Erise over the past couple of months that
`were not just restricted to April. I was also
`working in March and April.
` Q Other than Erise IP, do you recall
`other clients or other parties that were 11:11:47
`involved in cases that you worked on?
` A Fish & Richardson, I was involved.
`Perkins Coie was involved in one single case
`that I was finishing up. I have a few other
`clients, off the top of my head, but it has not 11:12:02
`been in the last few months.
` Q So to make a distinction between your
`client being the law firm and the party
`involved in the case, the actual parties that
`are litigating, do you recall other parties, 11:12:15
`other than Erise IP that were involved in cases
`that you represent?
` A The only thing that would be
`consistent is that I regularly work for Apple,
`and I don't have any sort of conflict beyond 11:12:29
`
`Page 15
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`that. Again, a lot of these cases, I do not
`know the details. Sometimes I don't even know
`who the opposing law firm is.
` Q Have you prepared expert declarations
`for each of these cases? 11:12:46
` A There are a few that I did not
`prepare declarations for, as I do not feel the
`evidence was sufficient enough to warrant a
`declaration.
` Q But most cases, you do prepare expert 11:12:57
`declarations for?
` A I would say between 80 and 90 percent
`of cases I do. If I don't believe that the
`recordkeeping holds up to what I'm asked to
`verify, I won't put out a declaration. 11:13:10
` Q For the Erise IP case, did you
`prepare an expert declaration for that case?
` A Not as of yet. For the last
`previously finished case, yes. I consider it
`to be finished when a declaration is completed. 11:13:23
` Q So for the last finished Erise IP
`case, did you prepare an expert declaration for
`that case?
` A Yes.
` Q And what was the subject matter of 11:13:32
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`Page 16
`the expertise that you provided your opinion on
`in that declaration?
` A Library records and publishing.
` Q And you noted that you regularly work
`for Apple and recently did a case where Apple 11:13:50
`was the client. Do you recall the last case
`subject matter?
` A The subject matter of the case, I do
`not recall. I believe it is broadly involved
`in the field of engineering or computer 11:14:06
`engineering, but my own personal knowledge
`doesn't fill in the gaps there. I'm not
`exactly sure to be specific.
` Q Do you recall the subject matter of
`your expertise that you provided on the opinion 11:14:17
`on the declaration in that case?
` A The subject matter of the expertise
`would be based on my library knowledge as I'd
`be using library records to verify the claim.
` Q You noted that you regularly work for 11:14:29
`Apple. Have you ever testified for Apple?
` A Sure. Testified or been deposed?
` Q Let's take that one at a time. How
`many times have you presented a deposition on
`behalf of Apple? 11:15:01
`
`Page 17
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` A I believe at least twice, and I've
`never been on the stand or in court.
` Q Have you been on the stand in court
`as far as work outside of any Apple cases?
` A No. 11:15:20
` Q Approximately how many cases have you
`testified on behalf of Apple in the
`declaration -- I'm sorry, in a deposition?
` A In a deposition, approximately two.
`I've done three depositions, and I don't know 11:15:37
`the whole details as to one of them.
` Q So you've done two depositions for
`Apple and one for another party, is that
`correct?
` A I'm not sure if the other one was for 11:15:50
`Apple or not.
` Q But in total, throughout your three
`plus years as an expert witness, you've done
`three declarations, is that correct?
` A Three depositions. 11:16:02
` Q Three depositions. And is Apple
`paying you to testify today?
` A I believe Apple is paying me through
`the law firm, yes.
` Q And how much is Apple paying you? 11:16:18
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`

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`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 9 of 15 PageID #: 24959
`Jaccob R. Munford
`June 19, 2020
`
`Maxell, Ltd. v. Apple, Inc.
`Page 18
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` A $100 per hour.
` Q And how many hours has Apple paid you
`so far in this case?
` A I have not invoiced for this case
`yet. 11:16:30
` Q When did you first start working on
`this case?
` A I don't know if I could tell you, off
`the top of my head. I'm sure it was two or
`three months ago, but these cases are filled 11:16:57
`with details and I couldn't say.
` Q So you started working in this case
`three months ago, but you have not submitted
`any invoices to Apple?
` A I have not submitted any invoices as 11:17:11
`the declaration was only finished a few weeks
`ago and I bill quarterly.
` Q And how many hours did you spend
`writing your expert declaration?
` A Writing this declaration, I would say 11:17:33
`approximately two to three hours.
` Q And did your attorney help you write
`it?
` A It was created with counsel's help,
`yes. 11:17:50
`
`Page 19
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` MR. LIANG: Objection here. I'm
`going to -- questions about who wrote what,
`that's protected under the discovery order,
`paragraph 12. And there has been objections on
`both sides to any questions on that subject, so 11:18:03
`I instruct the witness not to answer.
` THE WITNESS: Am I ready to answer?
` MR. LIANG: No, do not answer.
` THE WITNESS: Okay.
`BY MR. MIRANDA: 11:18:23
` Q So without going into any of the
`subject matter of what your attorney told you,
`speaking only as to yes or no, did your
`attorney help you write your expert report?
` MR. LIANG: That's still covered 11:18:38
`under the discovery order, paragraph 12.
`That's been clear throughout both sides'
`depositions -- expert depositions for the past
`week.
`BY MR. MIRANDA: 11:18:52
` Q Let me ask it a different way. Did
`you write the legal standards section of your
`report?
` MR. LIANG: That's also covered. The
`details of who wrote what, the writing of the 11:19:02
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`report are covered under paragraph 12 of the
`discovery report. That's privileged.
`BY MR. MIRANDA:
` Q Mr. Munford, are you following your
`counsel's instruction not to answer if you 11:19:16
`wrote the legal standards section of your
`report?
` A I would need to ask my attorney what
`his advice would be in that case.
` Q I'll ask again, Mr. Munford, did you 11:19:26
`write the legal standards section of your
`report?
` MR. LIANG: Same objection. You can
`consult with your other team members. We have
`an agreement not to talk about the details of 11:19:44
`the writing of the report, and that's been
`clear with your witnesses who have been
`testifying as well this week. So do not answer
`any questions, again, about the details of the
`preparation of the report. That's covered as 11:19:56
`protected and privileged under the discovery
`order paragraph 12.
`BY MR. MIRANDA:
` Q Mr. Munford, are you following your
`attorney's instruction? 11:20:09
`
`Page 21
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` A Can I ask you a question? Am I
`obligated to give you a yes or no answer?
` MR. LIANG: You can tell him if
`you're following my instruction, but no answers
`to questions about who did what on the report. 11:20:22
` THE WITNESS: Then I am following his
`instructions, yes.
`BY MR. MIRANDA:
` Q Are your opinions in your expert
`report yours? 11:20:38
` MR. LIANG: You can answer that.
` THE WITNESS: What's that? Could you
`repeat?
`BY MR. MIRANDA:
` Q Are your opinions in your expert 11:20:48
`report yours?
` THE WITNESS: Mark, could you repeat?
`I didn't hear what you said.
` MR. LIANG: I said you can answer
`that question, what he just asked. 11:20:56
` THE WITNESS: Gotcha. The opinions
`are mine, yes.
`BY MR. MIRANDA:
` Q And how many hours did you spend on
`your expert report that did not involve any 11:21:07
`
`6 (Pages 18 to 21)
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`

`

`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 10 of 15 PageID #: 24960
`Jaccob R. Munford
`June 19, 2020
`
`Maxell, Ltd. v. Apple, Inc.
`Page 22
`
`Page 24
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`attorney?
` MR. LIANG: Objection, privileged
`again. You're getting into the details of
`preparing a report that's covered under the
`order. I think what you can ask him -- I think 11:21:24
`you already did -- is how many hours he spent
`on the report.
` MR. MIRANDA: And, Mr. Liang, I'm not
`asking about any details or communication about
`the attorney and Mr. Munford, or any details 11:21:40
`involving an attorney. I'm simply asking, did
`the two or three hours that Mr. Munford said he
`worked on his report include or did not include
`an attorney.
`BY MR. MIRANDA: 11:21:57
` Q How many hours did you spend on your
`expert report that did not involve your
`attorney?
` A I can't help but believe that that is
`a question about how much an authorship the 11:22:04
`attorney has over the document. Is that
`correct?
` Q I asked you earlier, did you spend
`two or three hours in your expert report. Was
`that your own hours by yourself? 11:22:25
`
`Page 23
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` A I would --
` MR. LIANG: You can answer how much
`time you spent on the report.
` THE WITNESS: Yes, I spent two to
`three hours on the report. 11:22:38
`BY MR. MIRANDA:
` Q How many hours did you spend
`preparing for your deposition today?
` A I spent approximately two and a half
`hours preparing for the declaration -- or 11:22:53
`deposition. Sorry.
` Q And what did you do to prepare?
` A I did spend some time with the
`attorneys in the previous couple days to
`review, and then I spent about a half-hour on 11:23:08
`my own reviewing the declaration and the notes
`that I had taken from that meeting.
` Q Did you review any materials to
`prepare for your deposition today?
` A I'm sorry. What did you say? Could 11:23:22
`you repeat that?
` Q Did you review any materials to
`prepare for your deposition today?
` A Only the declaration itself.
` Q Did you review any of the exhibits 11:23:32
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`provided to you to prepare for your deposition
`today?
` A As part of the deposition, I was
`seeing that a copy of this declaration was sent
`forward as an exhibit. Is that what you're 11:23:53
`talking about?
` Q The expert report contains attached
`exhibits. Did you review those as well?
` A My expert report does, yes. I did
`review the exhibits. 11:24:04
` Q And do you have any documents or
`materials in front of you now?
` A Only the declaration.
` Q Mr. Munford, prior to being an expert
`witness as your main job, where were you 11:24:31
`employed?
` A You're asking, where was I employed?
` Q Yes.
` A I worked in libraries for
`approximately 10 years, from 2004 to early 11:24:38
`2016. I ended up getting extremely sick for a
`couple of years due to a nerve degenerative
`disorder, and I needed those years to recover.
`During the time I was in recovery, I had a
`friend who was doing some expert work and was 11:24:54
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`Page 25
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`looking to get out of the field as she was not
`being comfortable doing depositions. So after
`helping her with a handful of cases, I started
`picking up cases on my own to the point where I
`have enough cases on my own where I can make it 11:25:07
`part of my family's regular income.
` Q And how long -- you mentioned that
`you were employed for about 10 years in the
`library.
` A Yes. Yes. 11:25:26
` Q And were you employed in the library
`in the year 2000?
` A I was not employed in the library in
`the year 2000, no.
` Q How about in 1999? 11:25:36
` A No.
` Q Have you ever been employed at the
`University of Pittsburgh Library?
` A I have not.
` Q Have you ever been employed at the 11:25:45
`University of Pittsburgh at all?
` A I have never been employed by the
`University of Pittsburgh at all.
` Q Have you ever been employed by the
`Carnegie Mellon University Library? 11:26:05
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`

`Case 5:19-cv-00036-RWS Document 447-6 Filed 07/27/20 Page 11 of 15 PageID #: 24961
`Jaccob R. Munford
`June 19, 2020
`
`Maxell, Ltd. v. Apple, Inc.
`Page 26
`
`Page 28
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` A No, I have not.
` Q Have you ever been employed at the
`Carnegie Mellon University at all?
` A No, I have not.
` Q Do you have a graduate degree, 11:26:18
`Mr. Munford?
` A I have a master's degree in library
`and information science.
` Q And where is that degree from?
` A University of Wisconsin, Milwaukee. 11:26:29
` Q Did you desire to become an expert
`witness at trial using your degree?
` A I did not, no.
` Q Why not?
` A I didn't know this was a career 11:26:41
`opportunity open to me as a librarian. I only
`discovered it after I had become too infirm to
`serve in my regular library.
` Q What would you say that encouraged
`you to make this career change now? 11:26:56
` A What encouraged me to make this
`career change is that it deals with a lot of --
`the information required is the knowledge
`that's familiar to me, master's.
` Based on my own experience and my own 11:27:09
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`Page 27
`
`ability to speak on that experience. That's
`something I feel comfortable doing, so it
`seemed like a good fit.
` Q And you mentioned that your master's
`degree was in library and information science, 11:27:20
`is that correct?
` A Yes, I did.
` Q Does information science include any
`information technology?
` A It would depend on the definition of 11:27:32
`information technology. That's a very broad
`scope.
` Q Does it include any training on
`creating websites?
` A Yes. 11:27:42
` Q How so?
` A Because when you are interacting with
`a library catalogue, there is a back-end
`database of library information, such as
`patrons and users, and all those items and 11:27:58
`back-end database is displayed to the public on
`the front end of a website. So you have to
`have some knowledge of how these records are
`meant to interact with each other.
` Q Does having some knowledge on the 11:28:10
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`interaction of the records with the website
`involve development of the website?
` A Usually not. For the most part,
`library catalogues are second or third-party
`services which would then be integrated by the 11:28:27
`librarians themselves. But due to the
`complications of using library records, it is
`frequent that a librarian will have to look
`using those web design parameters to make the
`catalogue function. 11:28:40
` Q Does this training then include
`actual computer programming developed website?
` A Computer programming, developed
`websites? Could you be more specific? Are you
`speaking about HTML specifically or -- I guess 11:28:58
`I'm a bit confused here, because when I'm
`discussing a library catalogue, that is a
`website.
` Q So HTML is a specific language for
`computer programming. Regardless of the 11:29:13
`language used, did your training include in
`school any training of actual development of a
`website?
` A So MARC records used in library
`catalogues are a code used to be fed into a 11:29:33
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`Page 29
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`library catalogue application which then
`creates a website based on that code. So based
`on that, I would say yes.
` Q Outside of the MARC catalogue that's
`actually data used in that library catalogue 11:29:50
`application, does your training include actual
`development of the website code such as the
`website hosting code?
` A You're talking of website hosting on
`a server? I just want to make sure I 11:30:21
`understand what you're asking.
` Q Sure, I'm happy to