IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`
`1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
` APPLE INC., GOOGLE INC.,
` and MOTOROLA MOBILITY LLC
`
` Petitioners,
` v.
` ARENDI S.A.R.L.
` Patent Owner.
` ____________
` Cases:
` IPR2014-00206 (Patent No. 7,496,854)
` IPR2014-00207 (Patent No. 7,496,854)
` IPR2014-00208 (Patent No. 7,917,843)
`
` Thursday, August 7, 2014
` 9:03 a.m.
`
` DEPOSITION OF DANIEL A. MENASCÉ, Ph.D.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 1
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`2 (Pages 2 to 5)
`4
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`123
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` Deposition of DANIEL A. MENASCÉ, Ph.D,
`4 taken by Patent Owner at the Offices of Morrison &
`5 Foerster LLP, 2000 Pennsylvania Avenue, Northwest,
`6 Washington, D.C. before Randi J. Garcia, Registered
`7 Professional Reporter, and Notary Public in and for
`8 the District of Columbia, beginning at approximately
`9 9:03 a.m., when were present on behalf of the
`10 respective parties:
`11
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`13
`14
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`
` I N D E X
`3 DANIEL A. MENASCÉ, Ph.D
`4 DIRECT EXAMINATION PAGE
`5 By Mr. Asher 4
`
` ***No exhibits were marked.
`
`3
`
`5
`
`1 Thereupon,
`2 DANIEL A. MENASCÉ, Ph.D
`3 after having been first duly sworn, was
`4 examined and testified as follows:
`5 EXAMINATION
`6 BY MR. ASHER:
`7 Q Please state your full name for the
`8 record.
`9 A Daniel Alberto Menascé.
`10 Q I am going to show you a Notice of
`11 Deposition of Daniel A. Menascé, Ph.D.
`12 Are you the Daniel Menascé identified in
`13 this notice, which is paper number 11 in
`14 IPR2014206? It's paper number 11 in IPR2014207.
`15 It's paper number 13 in IPR2014208.
`16 A Yes, I am.
`17 MR. YAP: Counsel, are you going to label
`18 this at all as an exhibit? No?
`19 MR. ASHER: I just identified it by its
`20 paper number, to keep it clear.
`21 Q May I refer to IPR2014206 and 207 and
`22 208 as the 206IPR, the 207IPR and 208IPR?
`
`1
`A P P E A R A N C E S:
`2
`COUNSEL FOR
`PETITIONER APPLE, INC.
`3
`ALEX S. YAP, ESQUIRE
`MEHRAN ARJOMAND, ESQUIRE
`4 MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`5
`Los Angeles, CA 90017-3543
`(213) 892-5200
`6 marjomand@mofo.com
`ayap@mofo.com
`
`78
`
`COUNSEL FOR
`PETITIONERS MOTOROLA
`9 MOBILITY, LLC AND GOOGLE,
`INC.
`10
`JULIE TURNER, ESQUIRE
`TURNER BOYD LLP
`11
`2570 W. El Camino Real, Suite 380
`Mountain View, CA 94040
`12
`(650) 265-6109
`turner@turnerboyd.com
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`COUNSEL FOR PATENT OWNER, ARENDI S.A.R.L.
`ROBERT M. ASHER, ESQUIRE
`JOHN J. STICKEVERS, ESQUIRE
`SUNSTEIN, KANN, MURPHY & TIMBERS LLP
`125 Summer Street, 11th Floor
`Boston, MA 02110-1618
`(617) 443-9292
`rasher@sunsteinlaw.com
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 2
`
`

`
`6
`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`3 (Pages 6 to 9)
`8
`1 litigation cases I have been deposed several
`2 times.
`3 Q So I will quickly run through some
`4 reminders. I will be asking the questions and
`5 the court reporter needs to take down everything
`6 that both of us say.
`7 We should not speak over one another,
`8 because it makes it difficult for her to write
`9 everything down.
`10 Do you understand?
`11 A I do.
`12 Q When I am asking a question, please wait
`13 for me to finish before responding. I will do
`14 the same. If I pause, please wait for me to
`15 finish asking the question.
`16 A Sure.
`17 Q Please answer the questions aloud and do
`18 not nod or shake your head, as the court
`19 reporter cannot write that down.
`20 A I will do it.
`21 Q If you do not -- if you don't understand
`22 the question, please make me aware of it. I
`
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` A Right. I may not have a nice -- good
` identification of those numbers. It will be
` easier if you talk about the '843 patent and
` '854, and I used to refer to the '854 inserting;
` '854 performing. So it would make life easier
` for me, you know, unless, you know, you allow me
` to do some kind of small table here mapping
` those numbers. So, otherwise, we are going to
` get in trouble.
` Q Are you the Daniel Menascé who filed the
` declaration in the IPRs with respect to the '843
` patent and with respect to the '854 patent?
` A Yes, I am.
` Q And there were two declarations for the
` '854 patent, one in each of the IPRs, is that
` correct?
` A That is correct.
` Q Do you understand that today's testimony
` will be used as cross examination of your
` declarations for use in these three inter partes
` reviews?
` A I do.
`
`7
`
`9
`
`1 Q Have you ever been deposed before?
`2 A Yes.
`3 Q About how many times?
`4 A Maybe eight or nine times.
`5 Q What sort of cases have you been deposed
`6 in?
`7 A The majority -- most of them were patent
`8 infringement cases. There was only one trade
`9 secret, misappropriation case.
`10 Q When was the most recent time you have
`11 been deposed?
`12 A It was this year. I don't remember the
`13 exact date. It was the first semester of this
`14 year.
`15 Q Who was your -- who were you hired by
`16 for that deposition?
`17 A I was hired by Oracle. The law firm was
`18 Wilmer Hale.
`19 Q So are you generally familiar with the
`20 procedure for conducting depositions?
`21 A Yes, I am. I should say that this is
`22 the first deposition for an IPR case, but for
`
`1 will rephrase the question.
`2 A I will do that.
`3 Q Your attorney may want to object to
`4 certain questions. The way that will work is I
`5 will ask a question; your attorney might object.
`6 Then there will be an answer. Under the federal
`7 rules and the Patent Trial and Appeal Board
`8 rules you will need to answer the question
`9 unless your attorney instructs you not to
`10 answer.
`11 A I understand that.
`12 Q We will take periodic breaks during the
`13 day for convenience and comfort. There will be
`14 a lunch break as well. It is my practice that
`15 there are no breaks while there is a question
`16 pending. Only following an answer. If you need
`17 a break, please bring that to my attention.
`18 A I will do that.
`19 Q According to the -- now, this is with
`20 respect to the inter partes review -- according
`21 to the Patent Trial and Appeal Board practice
`22 from here on out you may not discuss the
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 3
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`4 (Pages 10 to 13)
`12
`
`10
`1 substance of the inter partes review proceedings
`2 and the patents at any time with your counsel
`3 until after the deposition has been completed.
`4 Is that understood?
`5 MS. TURNER: I don't think that is an
`6 accurate statement of the rule. I think it's
`7 while cross examination is continuing.
`8 We could obviously talk about that
`9 later, since I don't anticipate you will
`10 finish cross examination within the next
`11 hour.
`12 MR. ASHER: What I was going to point out
`13 next is exactly from the appendix of the Patent
`14 Office Trial Practice Guide it reads as
`15 follows, so we can all understand: "Once the
`16 cross examination of a witness has commenced,
`17 and until cross examination of the witness has
`18 concluded, counsel offering the witness on
`19 direct examination shall not consult or confer
`20 with the witness regarding the substance of the
`21 witness' testimony already given or anticipated
`22 to be given except for the purposes of
`
`1 A Four times.
`2 Q Which cases were those?
`3 A One case was the case I referred to, the
`4 trade secret, misappropriation case. The other
`5 three cases were cases related to patent
`6 infringement.
`7 Q What was the technical subject matter
`8 involved in those three patent infringement
`9 cases?
`10 A Okay. Let me try to remember, because I
`11 -- the first one, I believe, was a case
`12 involving CollegeNet. And the technology was
`13 technology for applying to college online or
`14 online applications.
`15 Q To call what?
`16 A When you apply for college, they have an
`17 online system for doing that. So that was the
`18 technology.
`19 The second time was the ePlus case, was
`20 a electronic sourcing technology. The other one
`21 -- the other case was a case of the multivariate
`22 negotiation system.
`
`11
`
`13
`
`1 conferring on whether to assert the privilege
`2 against testifying or on how to comply with the
`3 court order, or suggest to the witness the
`4 manner in which any questions should be
`5 answered."
`6 So do you understand that guideline?
`7 THE WITNESS: I do. I mean, I will leave
`8 that to the attorneys to figure out what is the
`9 -- whatever you tell me, you know, it's the
`10 right way to do it, I will.
`11 Q I guess you're right, until cross
`12 examination is concluded.
`13 What is your address?
`14 A 6477 Wishbone Terrace, Cabin John,
`15 Maryland 20818.
`16 Q Have you ever been involved in a
`17 litigation as a plaintiff or defendant?
`18 A As a plaintiff, no, no. Just as an
`19 expert witness.
`20 Q Have you testified at trial in the past?
`21 A Yes.
`22 Q How many times?
`
`1 Q So have you been engaged as an expert
`2 witness in this case?
`3 A In this case?
`4 Q In this case.
`5 A Well, in this IPR?
`6 Q Yes.
`7 A Well, yes. I believe that's -- I really
`8 want to make sure that I am giving you the right
`9 answer, because typically expert witness are for
`10 the litigations. I don't know if I am also
`11 called an expert witness. I guess I am.
`12 Q Who contacted you to work on these
`13 cases?
`14 A Well, I was contacted by a expert
`15 witness placement firm. They put me in touch
`16 with the attorneys for the case.
`17 Q Which attorneys were they -- were you
`18 put in touch with?
`19 A Mr. Alex Yap was the first one I talked
`20 to.
`21 Q And what was your assignment in this
`22 case?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 4
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`5 (Pages 14 to 17)
`16
`
`14
`
`1 MR. YAP: Objection to the extent it calls
`2 for work product information.
`3 You may answer.
`4 THE WITNESS: Okay. Well, my assignment,
`5 what I was told they were filing these
`6 petitions, and there was a need for a
`7 declaration from my part. And from that point
`8 on, you know, I started doing the work and
`9 interacting with them, reading the patents,
`10 studying them, studying the prior art, the
`11 usual thing.
`12 Q Who prepared your declaration?
`13 A I did.
`14 Q What role did the attorneys play?
`15 A Well, they gave me feedback. They had
`16 interactions, but it was my declaration.
`17 Q This is a portion of Exhibit 1002 in
`18 both IPRs, the 206 and 207. Do you recognize
`19 the document?
`20 A It seems to be my CV.
`21 Q And was the same CV submitted in all
`22 three IPRs?
`
`1
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` science at the same place. And then I got a
` Ph.D in computer science at UCLA.
` Q What was your field of specialty at
` UCLA?
` A My dissertation dealt with the issue of
` distributed databases. At that time networking,
` computer networking was really starting to
` become ubiquitous. So there was an issue
` whereby databases that were replicated over many
` different nodes of a computer network had to be
` synchronized. When you updated one node you had
` to make sure that the replicas of the data were
` synchronized with the other nodes in light of
` network of failures, node crashes and so on. So
` these distributed algorithms were really
` challenging, and my dissertation solved those
` problems.
` Q I hand you what is marked as Exhibit
` 1002. It comes from IPR2014-00207.
` Is this your declaration?
` A Yes. It seems to be.
` Q Do you have an understanding of the
`
`15
`
`17
`
`1 A The same CV, yes.
`2 Q Are there any corrections you believe
`3 should be made to the CV?
`4 A No. There were some additions. Since
`5 December of last year to now, you know, there
`6 were things that were added to my CV.
`7 Q Is the CV a true and accurate account of
`8 your work experience and accomplishments?
`9 A This is a true account up to December of
`10 2013, yes.
`11 Q Where did you go to college for your
`12 undergraduate degree?
`13 A The Catholic University in Rio de
`14 Janeiro, Brazil.
`15 Q What was your field of study?
`16 A Electrical engineering.
`17 Q What degree did you obtain?
`18 A Bachelor's, BS in electrical
`19 engineering.
`20 Q Did you go on to get any further college
`21 degrees?
`22 A Yes. I also got a Master's in computer
`
`1 meaning of a person of ordinary skill in the
`2 art?
`3 A I do.
`4 Q Is your understanding set forth in
`5 paragraph 28 of this declaration?
`6 A Yes. It is set forth in this paragraph.
`7 Q Do you have experience working with
`8 people of ordinary skill in the art?
`9 A I do.
`10 Q What is your experience in that respect?
`11 A I have been in academia as a professor
`12 in computer science since 1978. I have been
`13 teaching at all levels, Bachelor's, Master's,
`14 Ph.D. I was the advisor of 23 Ph.D students, 52
`15 Master students. I taught close to 100 courses
`16 over my career. So I deal with people of
`17 ordinary skill all the time.
`18 Q Can we agree that when I refer to a
`19 person of ordinary skill in the art or one of
`20 ordinary skill in the art I am referring to a
`21 person having experience described in your
`22 paragraph 28 of your declaration at the time of
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 5
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`6 (Pages 18 to 21)
`20
`
`18
`
`1 the invention of the '854 patent?
`2 A That is agreed. Thank you.
`3 Q I show you Exhibit 1008 --
`4 A Uh-huh.
`5 Q -- from the IPR 2014-00207.
`6 Do you recognize this as the
`7 Hachamovitch patent?
`8 A I do.
`9 Q Are you familiar with the Hachamovitch
`10 patent?
`11 A Yes, I am.
`12 Q Do you agree that Hachamovitch discloses
`13 a Word Completion Utility?
`14 A A Word Completion System.
`15 Q Are you uncomfortable with the term
`16 utility?
`17 A Well, if you read the first sentence of
`18 the abstract it says "a Word Completion System
`19 that can automatically predict unrestricted Word
`20 completions for data entries in an unstructured
`21 portion of a data file."
`22 So Hachamovitch refers to his invention
`
`19
`1 as a Word Completion System. In some portions
`2 he also refers as a utility.
`3 Q What is a utility?
`4 A Utility is a program.
`5 Q What distinguishes a utility from an
`6 operating system?
`7 A Well, an operating system has a very
`8 special purpose, and programs that are not part
`9 of the operating system run on top of the
`10 operating system and they require the resources
`11 provided by the operating system. These are
`12 very different types of programs in the sense
`13 that an operating system has unfettered access
`14 to the hardware resources. It can execute
`15 privilege instructions, such as halting the
`16 machine.
`17 Programs that run at the user level that
`18 are not system-level programs do not have those
`19 privileges. Everything they need has to be
`20 provided by the operating system. So if they
`21 need to access a file they need to go through
`22 the file system which is provided by the
`
`1 operating system, and so on and so forth.
`2 If they need memory, memory has to be
`3 allocated through the operating system, et
`4 cetera.
`5 So the operating system abstracts the
`6 resources of the machine and provides these
`7 abstractions to the programs that run on top of
`8 the operating system.
`9 Q Can a user launch and interact with a
`10 utility program?
`11 A It can if that utility is programmed to
`12 interact with users.
`13 Q Does Hachamovitch describe a utility
`14 that interacts with users?
`15 A Hachamovitch describes a program that
`16 interacts with other programs.
`17 Q So in order for the utility of
`18 Hachamovitch to interact with a user it has to
`19 first interact with another program, is that
`20 right?
`21 A Well, Hachamovitch is designed as a
`22 program that can interact and serve other
`
`21
`
`1 programs, and it is independent of the other
`2 programs that may use Hachamovitch.
`3 One thing that I think is important to
`4 understand in this whole context is as I was
`5 referring before what an operating system does
`6 is in order for you to run a program the
`7 operating system needs to create a process. A
`8 process is where a program runs, and the process
`9 has resources allocated to it by the operating
`10
` system, for example, memory and many other
`11
` resources.
`12
` So the invention of Hachamovitch is a
`13
` program that will run as a program as -- inside
`14
` the process provided by the operating system,
`15
` and there may be other programs that they refer
`16
` to here, like it could be a Word processor, for
`17
` example, would be a different independent
`18
` program.
`19
` Q So can the Word processing program
`20
` create a process that runs on the operating
`21
` system?
`22
` A The Word processing program does not
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 6
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`7 (Pages 22 to 25)
`24
`
`22
`
`1 create processes. When it is launched by the
`2 user, for example, when you double click on
`3 Word, what happens is that the operating system
`4 creates a process, assigns a process ID to the
`5 process, allocates resources to the process,
`6 memory, et cetera, and then loads the image of
`7 the Word program into memory. And from that
`8 point on the operating system dispatches, the
`9 CPU allocates time slices of the CPU to the
`10
` running program or running programs, so
`11
` basically you have many programs that are
`12
` running concurrently sharing the CPU. Each one
`13
` of them being given a time slice of the CPU by
`14
` the operating system.
`15
` So when, for example, if you have your
`16
` laptop; you're running, let's say, in one window
`17
` you're running Word, in the other Excel, in the
`18
` other your Outlook. All of these programs are
`19
` running at the same time.
`20
` By that I mean that if you have only one
`21
` processor, the operating system is providing a
`22
` time slice, let's say 100 milliseconds to the
`
`23
`1 Word processor. So it goes there and does some
`2 actions within 100 milliseconds. Then it loses
`3 control of the CPU and the operating system will
`4 give a time slice to your Outlook program and so
`5 on so forth.
`6 But for you, as a user, you have an
`7 impression that all are running concurrently.
`8 That's in a nutshell one of the things,
`9 important things that an operating system does.
`10 It is shared resources among different
`11 processes.
`12 Q As you described, Excel would run on one
`13 process?
`14 A Yes.
`15 Q And Word would run on another process?
`16 A Right.
`17 Q And Outlook would run on a third
`18 process?
`19 A Right.
`20 Q And the operating system would time
`21 slice and divide its time between several
`22 slices -- between several application programs?
`
`1 A Yes. Basically it will -- because the
`2 CPU is a shared resource, it will provide shares
`3 of the CPU to each of those programs in the
`4 sense that it will time slice. Time that will
`5 give slices of a time to each running process.
`6 So it does that in a way that the user
`7 does not proceed. For example, if the duration
`8 of time slice were to be too long, then one
`9 program could monopolize the CPU for too long
`10 and then as a user you would not have the
`11 impression that these programs are running
`12 concurrently.
`13 And there are other considerations, but
`14 if you want I can go into that but...
`15 Q When the Word processor described in
`16 Hachamovitch calls its Word Completion Utility,
`17 is a new process created?
`18 A No. Typically the Word Completion
`19 System would be running in a separate process.
`20 And in operating systems -- in fact, one of the
`21 things that operating systems do is they provide
`22 what is called inter-program communication
`
`25
`
`1 mechanisms or inter-process communication
`2 mechanisms. These are mechanisms by which one
`3 process can communicate with another process.
`4 For example, you could have a Word
`5 processor running in process A; Hachamovitch
`6 running in process B and they can communicate.
`7 So there are many inter-process
`8 communication mechanisms. One of them could be
`9 a remote procedure call, another could be a
`10
` service code. This process would be providing
`11
` some services to another program. And there are
`12
` message passing. This is another exactly of a
`13
` service provider mechanism, I should say
`14
` provided by the operating system, to allow
`15
` programs to communicate with one another.
`16
` So the actual way by which the
`17
` communications implemented can vary. It was
`18
` known to a person of ordinary skill in the art
`19
` way, way before 1998. I mean, any operating
`20
` system textbook would talk about that.
`21
` Q So if the Word processing program calls
`22
` the Word Completion Utility, the two of them
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 7
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`8 (Pages 26 to 29)
`28
`
`26
`
`1 share the same process on the operating system?
`2 A No. They don't. No. They don't. As I
`3 explained before, each one is running on its own
`4 process. And they can communicate and they are
`5 still running on their separate processes. They
`6 can exchange messages through the operating
`7 systems, for example, by which, for example, the
`8 process in which Word is running can send a
`9 message to the other process with some
`10
` parameters. The other process can act on that
`11
` and send parameters back. That is one example
`12
` of inter-process communication.
`13
` But they are independent in the sense
`14
` that the operating system is time slicing these
`15
` processes. It's sharing the CPU among these
`16
` processes.
`17
` Q So when the Word processing program is
`18
` running, it has a process assigned by the
`19
` operating system, is that right?
`20
` A Right. Correct.
`21
` Q And if it calls a Word Completion
`22
` Utility, what happens in terms of the process?
`
`1 with a process that is being used to run
`2 Hachamovitch.
`3 So by doing that, these processes, Word
`4 Excel, Outlook, they can request Hachamovitch to
`5 perform some tests, such as, for example, give
`6 me a suggested list of completions for this
`7 partial entry. Hachamovitch would then do its
`8 job and return that list to whoever requested.
`9 Could be Microsoft Word, could be Excel. Could
`10
` be Outlook.
`11
` Q If I refer to Figures 2A through C of
`12
` Hachamovitch, do you see items 208, 208 prime
`13
` and 208 double prime?
`14
` A I do.
`15
` Q What are 208, 208 prime and 20 double
`16
` prime?
`17
` A Well, this is showing that the user is
`18
` typing here. For example, let's take a look at
`19
` 208. The user is typing today is June, and the
`20
` user typed only JUN. And at this point the Word
`21
` processor makes a request to Hachamovitch and
`22
` asked for a suggested completion, list of
`
`27
`
`29
`
`1 A Well, typically this Word Completion
`2 Utility or program is running on a separate
`3 process. And one of the deployments that
`4 Hachamovitch discloses here -- let me go to the
`5 citation for you.
`6 So, for example, if you go to column
`7 seven, starting on line 65 it says
`8 "alternatively, the Word Completion System may
`9 be deployed within an operating system or as a
`10
` standalone utility that may operate on an
`11
` application independent basis.
`12
` Application independence is the ability
`13
` of the same Word Completion System to work with
`14
` several different application programs, such as
`15
` a Word processing program, an e-mail program, a
`16
` spreadsheet program, a personal calendar program
`17
` and so forth."
`18
` So in this embodiment disclosed by
`19
` Hachamovitch what that means is that
`20
` Hachamovitch is running as a separate process,
`21
` and other processes such as the ones on which
`22
` Word, e-mail, Excel are running, can communicate
`
`1 completions.
`2 A completion list pops up on top of the
`3 word JUN to indicate that a completion can be
`4 done using June 26, 1997.
`5 In the next figure we have something
`6 similar. We have MIC being typed, and then a
`7 pop-up window will show a possible completion,
`8 being Microsoft Corporation and that's again
`9 provided by Hachamovitch.
`10
` In the last one, Figure 2C shows that
`11
` you are typing VER probably, you know, you're
`12
` typing a letter, and then Hachamovitch is
`13
` requested for completion and it returns "very
`14
` truly yours."
`15
` Q Does the request to the utility program
`16
` happen after, you said, JUN?
`17
` A After you type JUN the Word processor in
`18
` this case will make a request to Hachamovitch to
`19
` the program, and then Hachamovitch will then go
`20
` through a possible list of completions and
`21
` provide completion back to the Word processor.
`22
` So this is what user sees. The user
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 8
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`9 (Pages 30 to 33)
`32
`
`30
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` sees this pop-up window.
` Q What about after you type just JU, is
` there a request at that point?
` A Well, typically, I mean, Hachamovitch
` contemplates some mechanisms and some rules by
` which it will, for example, say if we go -- let
` me go -- let's go to Figure 5, for example. In
` Figure 5, if you look at step 504, here
` Hachamovitch is asking the question minimum
` number of characters since less delimiter.
` Basically the idea is that maybe if you
` just type one letter, you don't want to be, you
` know, looking for other completion for just one
` letter, because you could have a humongous list,
` right?
` So I think that one parameter that can
` be used by Hachamovitch is the minimum number of
` characters. After two letters or after three
` letters, then you can get another completion,
` something like that.
` If you follow this flowchart in Figure 5
` you will see after Hachamovitch comes up with
`
`31
`1 the completion in the Word Completion Field, if
`2 the user says, okay, user selects one of those
`3 completions in that list, then Hachamovitch
`4 replaces the current data, current data meaning
`5 the partial entry with the completion on step
`6 518 of Figure 5.
`7 Q Which program is performing that step
`8 504 minimum number of characters since last
`9 delimiter?
`10
` A Hachamovitch.
`11
` Q That would be the Word Completion
`12
` Utility?
`13
` A It would be the Hachamovitch program.
`14
` So if you look at Figure 5, Figure 5 is
`15
` Hachamovitch. It's a flowchart of what is going
`16
` on here. There is a -- when the Word processor
`17
` or someone is typing something in the Word
`18
` processor these partial entries are being passed
`19
` to Hachamovitch, and Hachamovitch will execute
`20
` its algorithm, its flowchart which is shown in
`21
` Figure 5.
`22
` So it is looking at what is being typed.
`
`1 It says "minimum number of characters, yes or
`2 no. Is there an unambiguous match to a name
`3 entry?" This is something else that
`4 Hachamovitch does when it provides a list of
`5 completions. It makes sure that at least one of
`6 those could be an unambiguous match. That is
`7 the way they decide to do it.
`8 There are some other questions here.
`9 "Does context and capitalization match?"
`10
` Finally, step 514 you display completion
`11
` in the Word completion field, and you receive a
`12
` completion code and then Hachamovitch replaces
`13
` the current data item with the completion.
`14
` Q So is that it each time one enters a
`15
` character into the Word processing program, that
`16
` process stops and moves to the Hachamovitch
`17
` process?
`18
` A It doesn't have to stop. It doesn't
`19
` have to stop. I mean, like I explained before
`20
` to you, you have two processes running
`21
` concurrently, and they can be communicating with
`22
` each other and a process does not have to stop
`
`33
`
`1 -- I mean, there are several -- in operating
`2 systems are there several ways of communicating.
`3 One is called synchronous communication.
`4 And the other is asynchronous communication.
`5 Synchronous communication would mean
`6 that you send a message or you make a request to
`7 another program and you wait for that reply to
`8 move on.
`9 Asynchronous means that you make a
`10
` request and keep doing what you're doing, and
`11
` eventually you may receive a reply and you act
`12
` on that reply.
`13
` These are just implementation details.
`14
` These are just things that were known to a
`15
` person of ordinary skill in the art, so they
`16
` could choose many different ways to implement
`17
` this interaction. And that would be up to
`18
` whoever is doing the implementation. These were
`19
` all known techniques by -- actually way before
`20
` 1998.
`21
` Q If the machine has a single processor,
`22
` are you saying it can run more than one process
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Apple Inc., Google Inc. and Motorola Mobility LLC
`Exhibit 1013 - Page 9
`
`

`
`IPR2014-00206, IPR2014-00207, IPR2014-00208
`August 7, 2014
`Menasce, Ph.D., Daniel A.
`10 (Pages 34 to 37)
`36
`
`34
`
`1 at the same time?
`2 A Oh, yes. At the same time. And when I
`3 say at the same time I mean, logically speaking,
`4 if you only have one processor, you have many
`5 processes using the CPU at the same time,
`6 logically speaking.
`7 In the sense that, because the time
`8 slice is typically very short, what happens is
`9 that users do not perceive t