`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`CANON INC., CANON U.S.A., INC., CANON FINANCIAL SERVICES,
`INC., FUJIFILM CORP., FUJIFILM HOLDINGS AMERICA CORP.,
`FUJIFILM NORTH AMERICA CORP., JVC KENWOOD CORP.,
`JVCKENWOOD USA CORP., NIKON CORP., NIKON INC., OLYMPUS
`CORP., OLYMPUS AMERICA INC., PANASONIC CORP., PANASONIC
`CORP. OF NORTH AMERICA, SAMSUNG ELECTRONICS CO., LTD.
`and SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioners,
`v.
`
`PAPST LICENSING GMBH & CO. KG
`Patent Owner.
`____________
`
`Case IPR2016-01199 and IPR2016-01214
`Patent 8,966,144
`Case IPR2016-01200 and IPR2016-01213
`Patent 8,504,746
`____________
`
`Record of Oral Hearing
`Held: September 14, 2017
`____________
`
`
`
`
`Before JONI Y. CHANG, MIRIAM L. QUINN, and JENNIFER S. BISK,
`Administrative Patent Judges.
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`Case IPR2016-01199 and IPR2016-01214 (Patent 8,966,144)
`Case IPR2016-01200 and IPR2016-01213 (Patent 8,504,746)
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`APPEARANCES:
`
`ON BEHALF OF PETITIONER:
`
`
`T. VANN PEARCE, ESQUIRE
`Orrick Harrington & Sutcliffe, LLP
`1152 15th Street, N.W.
`Washington, D.C. 20005
`(202) 339-8400
`
`
`ON BEHALF OF PATENT OWNER:
`
`
`NICHOLAS T. PETERS, ESQUIRE
`PAUL B. HENKELMANN, ESQUIRE
`Fitch, Even, Tabin & Flannery, LLP
`120 South LaSalle Street, Suite 1600
`Chicago, Illinois 60603-3406
`(312) 577-7000
`
`RACHE M. CAPOCCIA, ESQUIRE
`Jeffer Mangels Butler & Mitchell, LLP
`1900 Avenue of the Stars 7th Floor
`Los Angeles, California 90067
`(310) 201-3521
`
`
`
`
`
`
`
`
`
`
`
`The above-entitled matter came on for hearing on Thursday,
`
`September 14, 2017, at 9:58 a.m., at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`P R O C E E D I N G S
`- - - - -
`JUDGE CHANG: I'm Administrative Patent
`Judge Joni Chang. Here with me is Judge Jennifer Bisk.
`Some of you we heard from yesterday, but I think some
`of you had not met us yesterday. Judge Miriam Quinn is
`joining us remotely from Texas. Good morning, Judge
`Quinn. I just want to double-check if you can hear us?
`JUDGE QUINN: Yes, I can hear you. Thank
`
`you.
`
`JUDGE CHANG: Counsel, please introduce
`yourself and your colleagues.
`MR. PEARCE: Good morning, Your Honors.
`Van Pearce on behalf of the petitioners and since we've
`got a smaller audience here today, I think I can introduce
`everyone. With me is Chris Higgins, from my firm.
`MR. HIGGINS: Good morning, Your Honor.
`JUDGE CHANG: Good morning.
`MR. PEARCE: And then going around the room
`Rachel Capoccia, Kerry Byer, Mark Blackman, all of
`whom are counsel for some of the petitioners. Dr. Paul
`Reynolds, our expert witness. Herbert Finn, for LG and
`Andrew Decar for Olympus.
`JUDGE CHANG: Good morning. Thank you.
`MR. PETERS: Good morning, Your Honor.
`Nicholas Peters on behalf of the patent owner, Papst
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`Licensing, and my colleague, Paul Henkelmann, who
`will also be presenting today. And also, litigation
`counsel for Papst we have joining us Jonas David and
`Richard Paul.
`JUDGE CHANG: Good morning. Thank you so
`much. Sorry, about the small room. This is the
`consolidated oral hearing for IPR2016-01199 and 1200,
`1213, 1214 involving patent 8,966,144 and 8,504,746.
`Before we begin, I have a few procedural matters to go
`over. Just to make the record clear for this particular
`oral hearing, it is open to the public and the transcript of
`this hearing will be entered into the official file of each
`of the IPR proceedings, as well as, in the record of
`IPR2016-01211, 1212, 1216 and 1225.
`Those are the IPRs that we had the hearing
`yesterday, which involve the same patents and same
`claim construction issue. And please just remember to
`speak at the podium so that Judge Quinn can hear us and
`also when you refer to a particular slide make sure that
`you identify the slide. Petitioner will go first and only as
`to the arguments for IRP2016-01199 and 1200 involving
`prior art Aytac. Each party will have 45 minutes for its
`argument as to these two IPRs.
`And then after the petitioner presents its main
`case, then the patent owner will respond to the
`petitioners' argument and then petitioner may reserve a
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`small portion of its time for rebuttal. And then we will
`take 15 minute break and then when we come back to
`continue with the arguments regarding IPR2016-01213,
`and 1214, regarding the prior art reference Yamamoto
`and using the same format each party will have 45
`minutes to present its argument. So, is there any
`questions regarding the format?
`MR. PETERS: No, Your Honor.
`MR. PEARCE: No, Your Honor.
`JUDGE CHANG: Great. Thank you so much.
`Petitioner counsel you may begin anytime you like.
`MR. PEARCE: Before I begin, I do have copies
`of my demonstratives, hardcopies.
`JUDGE CHANG: That's great. Thank you.
`MR. PEARCE: May I approach?
`JUDGE CHANG: Yes. Did you provide a copy
`to JUDGE CHANG reporter?
`MR. PEARCE: Yes, Your Honor. I did.
`JUDGE CHANG: Okay. Thank you.
`MR. PEARCE: Just to confirm, Judge Quinn you
`can hear me okay?
`JUDGE QUINN: Yes, thank you, I can hear you.
`MR. PEARCE: Thank you. I'll try to remember
`to look at the camera if I'm addressing you. It's a little
`awkward here because you're on the sidewall there. But,
`I'll do my best.
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`JUDGE QUINN: Yes, the camera that I see is the
`one in front of you, right behind the Judges.
`MR. PEARCE: Thank you. Your Honor, I'd like
`to reserve eight minutes of my time for rebuttal.
`JUDGE CHANG: Okay.
`MR. PEARCE: So, if I may, what I would like to
`do is start with an overview of the reasons why the
`challenged claims are unpatentable and some of the key
`issues in this two set of IPRs 1199 and 1200, dealing
`with the Aytac primary prior art. Aytac describes the
`system that does everything disclosed in the challenged
`claims of both the 144 and 746 patents. Aytac also
`discloses a number of other useful features and
`functions. Aytax discloses a device called the CaTbox
`that uses the same hardware and software disclosed in
`the two challenged patents, the SCSI interface and
`standard SCSI drivers called ASPI drivers.
`It uses that hardware and software for the same
`purpose, to facilitate communication and transfer files,
`between various peripheral devices, like scanners, fax
`machines and so on and a computer. Now, this may
`seem a little bit familiar if you remember from
`yesterday's arguments, there are a number of similarities
`between Aytac and Kowaguchi McNeill.
`But, unlike the arguments yesterday, here the
`patent owner has not argued that Aytac doesn't disclose
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`files or file systems. There's no contingent that Aytac is
`some sort of data relay device. In fact, there really aren't
`any disputed technical issues of fact about Aytac at all.
`The dispute really boils down to what these claims
`cover.
`And the problem with all of the patent owner's
`arguments that is that they are not tied to anything in the
`claim language. The patent owner's primary argument is
`that Aytac's preferred embodiment discloses a file on the
`computer, or a driver rather, called CATSYNC and that
`this driver violates the challenged claims limitation that
`deals with automatic file transfer.
`But, that limitation, in relevant part, only says that
`the system must be able to transfer one file from the
`interface device the ADGPD to the computer without
`requiring any user loaded software. The evidence here,
`the testimony of both sides' expert witnesses establishes
`that the Aytac system indeed can transfer one file
`without using CATSYNC.
`CATSYNC instead just provides some of the
`more advanced features and functionality that are
`disclosed in Aytac and that are not claimed in the
`challenged claims and do not even disclose anywhere in
`the challenged patents. So, comparing the actual claim
`language here to the facts about the prior art that are not
`in dispute, these are the conclusion that all the
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`challenged claims are unpatentable.
`JUDGE CHANG: So, for those features a user
`will have to load those software?
`MR. PEARCE: Right. So, the preferred
`embodiment of Aytac discloses CATSYNC, along with
`another number of programs on the computer. The
`features and functions provided by CATSYNC, as
`disclosed in Aytac itself, and as both sides expert
`witnesses agree to are to provide a degree of
`synchronization between the processor --
`JUDGE CHANG: But those features require a
`user to load those software?
`MR. PEARCE: In that particular embodiment
`that software CATSYNC, yes that is not a standard
`driver. That would be a driver that is specific to the
`CATSYNC invention. So, I turn to begin with to slide
`number four, this just provides an overview of the 1199
`IPR. And the one disputed issue -- issue disputed by the
`patent owner in the 1200 IPR is the same automatic file
`transfer limitation.
`So, I plan to address my remarks today to the
`1199 petition and my citation to the record will be to that
`petition unless stated otherwise. Moving to slide five,
`this lists the three issues that are at dispute for the 1199
`patent.
`And again, I plan to focus my remarks today on
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`these issues that the patent owner has contested, the four
`subjects and any questions Your Honors may have. If I
`turn to slide 16 to go to the first disputed issue, it deals
`with this claim limitation regardless of the identity of a
`manufacturer of the computer.
`Now, this issue was raised second in the patent
`owner's response and therefore we addressed it second in
`our reply brief. Going to it here first just because it
`appears first in the claim language and it's also a fairly
`straightforward issue. Slide 17 shows the relevant claim
`language.
`So, both the automatic recognition process
`limitation and the automatic file transfer process
`limitation of the challenged claims includes this clause
`that says the process must happen regardless of the
`identity of a manufacturer of the computer. And the
`parties have agreed that across the independent claims,
`while there are some differences in the language, the
`issue is the same.
`And the patent owner's argument here is that the
`Aytac reference only works with a computer, the Aytac
`system, the CaTbox system, only works with a computer
`that runs Windows 95 and that this violates this
`regardless of who the manufacturer is. Now, that's
`actually not correct. Aytac is not limited to working
`with Windows 95.
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`But, even if that were true, that would still suffice
`to meet this limitation. If we turn to slide 19, what I
`have here is an excerpt from the file history of the 144
`patent. This is the patent applicant's remarks explaining
`this limitation when they admitted the claims to add this
`regardless of the manufacturer language.
`What they explained here is just really what the
`language says, it's regardless of the manufacturer of the
`computer, not regardless of the manufacturer of the
`operating system. So, they gave us a specific example
`of what will meet this claim language. Two computers,
`one a Compaq computer, one a NEC computer, both
`running Windows 95. If the device can work with both
`of those computers, that suffices to meet this language.
`That's exactly what Aytac discloses even by the
`patent owners own reading of it. Aytac discloses using
`Windows 95 on the computer in its preferred
`embodiment. But, doesn't say anything about any
`limitations as to the manufacturer. And of course, there
`are many computer manufacturers make computers that
`use Windows 95.
`Turning to slide 20, this is the testimony from Mr.
`Gafford at his deposition, the patent owner's expert,
`where he did indeed agreed that a CaTbox system could
`communicate with the host computer regardless of the
`identity of the manufacturer of the computer. I'll pause
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`here to make one point.
`We've cited Mr. Gafford's deposition testimony in
`a number of places in our reply brief and I have a
`number of excerpts of his testimony in my
`demonstratives. I would encourage Your Honors to pay
`attention to his testimony. It really undermines the
`patent owner's argument on every point.
`JUDGE CHANG: You made a point that even if
`a manufacturer does not use Windows 95, can also still
`use the CaTbox. Do you have evidence as to that issue?
`MR. PEARCE: Yes, Your Honor, and that's
`actually my next point. I can go to slide 21. CaTbox, in
`its preferred embodiment, describes a system where
`Windows 95 is the operating system on the computer.
`The CaTbox is not limited to that. There's nothing in
`CaTbox that says it's limited to that. To the contrary,
`CaTbox discloses using the standard SCSI drivers. The
`standard SCSI interfaces for communication between the
`computer and the CaTbox system.
`SCSI by definition is a standard. It is not limited
`to any sort of computer system or device manufacturer.
`The record evidence shows that SCSI was used, in fact,
`in Apple computers and computers running other types
`of operating systems at the time. The fact that SCSI is
`device independent is I think not reasonably disputed,
`that was the testimony of our expert, the 144 patent
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`itself, and it discusses that in its discussion of what was
`known in the prior art.
`Then if we turn to slide 22, again, this is
`testimony from Mr. Gafford confirming that SCSI was
`an operational in computers made by different
`manufacturers. So, that again, that's our contention is
`that it's not limited to Windows 95, but even if it was
`that still would not be a relevant distinction here.
`I'll turn to the next dispute and this is really where
`the patent owner has devoted most of its attention. Let's
`turn to slide 23 and I'll actually just go to slide 24 that
`has the claim language. It deals with the automatic file
`transfer limitation. The claim language here is important
`so I want to make sure that we look at this in detail.
`What this claim says is that the ADGPD or
`interface device, its processors -- that its processor is
`adapted to be involved in an automatic file transfer
`process in which the processor causes the at least one
`file of digitized analog data to be transferred to the
`computer without requiring any user loaded file transfer
`enabling software to be loaded on or installed in the
`computer at any time.
`The key dispute here is whether the Aytac
`reference violates this without requiring clause, this
`negative limitation at the end of the claim. And the
`answer is that it doesn't because Aytac's disclosed
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`system do not require any user loaded software in order
`to do what the claim calls for. To cause the transfer of
`the at least one file of data from the CaTbox to the
`computer.
`There are a few points as to the meaning of the
`terms in these claims that are important and I want to
`cover next. I'm going to move to slide 27. I'll point out
`to begin with, that while these really aren't claim
`construction type issues, or issues about what the claims
`cover. The patent owner has not argued that the
`constructions adopted by the board to these terms and
`the institution said you were wrong.
`The patent owner hasn't proposed any other claim
`construction. So --
`JUDGE CHANG: For this case, the patent owner
`does disagree with the claim construction on “end user.”
`So, when you talk about user loading software, does it
`matter that we construe “end user” as a user to include a
`system administrator or not?
`MR. PEARCE: That issue is not relevant to the
`disputed points raised by the patent owner. The reason
`why it's not disputed that's all explained here in some
`detail. Is that the so called specialized software on
`Aytac, the CaTbox, is not required to do what the claim
`calls for. It's not required for file transfer. So, we don't
`even get to the question of whether that software is user
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`loaded, or end user loaded, or if there's a difference
`between those two, because whether it's on the computer
`or not it's irrelevant.
`It could be there. It could not be there. It's not --
`JUDGE QUINN: But, counsel, if we found that
`the CATSYNC driver is required, would we then have to
`reach the issue that my colleague just referred to of
`deciding whether the loading of that software is done by
`an end user or user administrator?
`MR. PEARCE: So, Your Honor, I don't think you
`would and again, I would urge that we don't need to
`reach that issue, but if you did one point to keep in mind
`here is that the disclosure of CATSYNC in the Aytac is
`part of the preferred embodiment. That Aytac has other
`disclosures beyond that.
`Now, again, to be clear, we're fine with preferred
`embodiment if preferred embodiment works, but the
`CATSYNC disclosure is only part of that embodiment.
`Aytac, more broadly, discloses using SCSI
`communications to communicate between those CaTbox
`device and those computers. Aytac also discloses that
`there are a number of different uses and functionalities
`of Aytac when, for example, we pointed out in our reply
`brief, is that Aytac can work.
`It says in Aytac as a remote hard disk for the
`computer which is an example the patent owner gave of
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`a situation where you wouldn't need CATSYNC, or it
`would operate without CATSYNC. So, to answer your
`question, no we don't need to reach that issue. I will say
`on the point on end user versus user although again I
`don't think it's relevant here.
`The board's construction I believe was that the end
`user was the ultimate user of the computer in its final
`finished form. We agree with that construction, but the
`patent owner in disputing that in response, it points to
`various aspects of things in the prosecution history for
`example, the prosecution history of this patent, these
`patents were very long.
`There are a lot of different things that were said at
`different points in time. You can find cherry picked
`points if you're going both way on a user versus end user
`point. I mean that doesn't really rise to the level of
`overriding the fact that there are two different terms used
`here that in the ordinary part have different meanings.
`So, in conclusion, on that we believe that board's
`construction was correct and we also don't think the
`board will need to address that issue.
`JUDGE QUINN: Okay. I don't think you
`answered my question. So, if we find that the
`CATSYNC driver is required for the CaTbox to operate,
`the claim says there is no requirement for the user loaded
`file transfer enabling software to be loaded on or
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`installed in a computer in addition to the operating
`system. So, that loading, or installing of that, does it
`need to be performed by any particular person in these
`claims?
`MR. PEARCE: I think I understand your question
`now and I apologize that I didn't address it previously.
`So, in this claim limitation, you're right, it says user and
`it doesn't say end user. So, if we're looking at the
`distinction between user and end user, end user appears
`elsewhere. I don't think that that relates here to this
`automatic file transfer limitation because it just says user
`loaded.
`And so, I don't think there's a need to resolve that
`dispute. And then the question of what does a user
`mean, I think the board's construction of end user was
`that it was the ultimate user of the computer. I don't
`think there was a construction of user. As I mentioned
`earlier Judge Chang in response to your question, the
`fact that the CATSYNC driver is not a standard driver
`that was known in the arts outside of Aytac, it wasn't
`like a SCSI driver for example.
`So, from that perspective it would be something
`that was created just for the purposes of CATSYNC and
`Aytac mentioned in that preferred embodiment. So, if I
`can move on to slide 27, again, looking at the claim
`language here. So, and this goes to the question of well,
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`what is in fact required to meet this claim language?
`The automatic file transfer limitation says that the
`transfer happens without requiring user loaded software.
`It does not say and that does not mean it is prohibiting
`user loaded software. That's a basic principal of claim
`construction law that the federal circuit does address
`that. We cited a case directly on point in our brief.
`The Celsis In Vitro case in our reply brief. Mr.
`Gafford also confirmed that was his understanding of
`this language. So, as he pointed out here, as long as the
`software is not required to meet the claim limitation, the
`computer can have any number of pieces of software
`installed.
`So, when we look at Aytac, the question is not
`does it have user loaded software? It doesn't matter
`necessarily if it does. The question is, is that software
`required to do what is claimed. And what is claimed
`here is the transfer of the at least one file of data and that
`would be met by the transfer of one file or data. At least
`one means one or more.
`Again, there's case law on that point we cited in
`our brief. The Z4 Text case and this is consistent with
`what Your Honor said in the institution decision about
`sending a digitized analog data file to the computer and
`that's in slide 28.
`In slide 29, it's consistent with how at least in one
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`place the patent owner characterized the invention, this
`is in their response pages one and two. The 144 patent
`claims the process to cause a file of digitized data to be
`transferred to the computer and again going to slide 30,
`it's consistent with Mr. Gafford's understanding he
`understood this claim to mean.
`JUDGE CHANG: But, isn't it the CATSYNC
`driver is used in the file transfer function?
`MR. PEARCE: That CATSYNC driver, if it is
`installed, as in the preferred embodiment will be
`involved in the file transfer function. The way it is
`involved is as it says in Aytac, it hooks the call from the
`computer to the CaTbox. So, it will be involved in that
`process. It functions in that sense like a passer and the
`functions that it performs are as it says in Aytac, and that
`as the parties' experts agreed to are the synchronization
`function and this data function.
`But, it also says in Aytac, that CATSYNC works
`in tandem with the ASPI drivers that are on the
`computers. Those are the standard SCSI drivers. And
`the evidence here shows that those drivers, the SCSI
`drivers alone, are sufficient to transfer one file in the
`Aytac system, just as they are in the Tasler patents.
`I'll get to that point now in a little more detail. So,
`the question you raised here is what is this CATSYNC
`file doing and is it, in fact, required to what the claim
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`calls for? Turn to slide 35, and I've shown here an
`excerpt of Dr. Reynolds' declaration. Dr. Reynolds
`explained in some detail in his declaration and we did it
`as well in our petition.
`In which it is summarized here in this slide, is that
`in the Aytac system four things are necessary on the
`computer in order to have the transfer of a file. You
`need an operating system. You need a SCSI interface.
`You need a SCSI connection to the CaTbox and then
`you need device driver support for the SCCI interface.
`In other words, the ASPI driver, the standard
`SCSI driver. Now, this paragraph he's talking here about
`the automatic recognition process, but he confirmed later
`that the same is true for the file transfer process. That's
`on paragraphs 111 through 18 of his declaration.
`I want to pause here and this is an important point.
`None of this testimony from Dr. Reynolds about how
`SCSI would work in the CaTbox system and how these
`were the four things that were needed to transfer a file,
`the patent owner and the patent owner's expert did not
`address any of this. They did not contest any of this
`explanation of how SCSI operates and how SCSI would
`operate in the file system, or in the Aytac system.
`They talked about CATSYNC, but the underlying
`facts here about SCSI communications and how they
`would work here were not disputed. In fact, because of
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`that I'm not going to go through that in great detail
`unless Your Honors have further questions. But, I do
`want to make a couple of points here.
`Turn to slide 38, it shows side by side the 144
`patent and the Aytac disclosure. They both disclose
`using standard known SCSI commands such as the
`inquiry command. Aytac explicitly tells those skilled in
`the art that the CaTbox looks like a SCSI used PC. So,
`it's emulating a SCSI disk and it directs those skilled in
`the art to the SCSI specification.
`So, one reason this patent would know if I don't
`understand how this works, I need to go look at a SCSI
`specification. Which then lays out in great detail how
`there's a recognition process using the inquiry command
`so it can exchange file system information and how you
`can transfer files using SCSI commands.
`If I turn to slide 39, it goes even further in terms
`of the similarities between these two patents. They both
`disclose explicitly using the same type of driver on the
`computer, the so called ASPI driver, the advanced SCSI
`programming interface driver. So, file transfer would be
`possible in the Aytac system using just the SCSI drivers
`that are disclosed just as it is in the Tasler patents.
`So, what's the patent owner's argument? I'm
`going to turn to the next slide 40. The patent owner has
`argued that Aytac has these specialized drivers and they
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`focused on the CATSYNC driver. And they argue that it
`would be necessary to modify Aytac to remove those
`drivers in order to reach the challenged claims and that
`that modification would be impermissible.
`And again, that's shown on slide 41 what they
`focus most of their attention on here is the CATSYNC
`driver. So, the question we have to answer here is, is
`CATSYNC required to transfer at least one file? I asked
`Mr. Gafford about this in his deposition, turning to slide
`44. I asked him if CATSYNC was not present on the
`host device and I asked him about one of his theories
`that there be this difficulty because you have to have a
`stale copy of the file in the cache memory of the
`computer.
`He said in that circumstance a copy of the file
`previously would have been transferred from the
`CaTbox to the PC, right? He answered yeah, you got a
`stale file. So, he has acknowledged here and this by the
`way was completely consistent with his declaration.
`That indeed, there would be a file transferred even if
`CATSYNC wasn't there or wasn't used.
`That's all that the claim here requires. Our expert,
`who is in agreement, Dr. Reynolds if you turn to page 46
`or slide 46.
`JUDGE BISK: I have just one quick question, I'm
`wondering -- so say we're going to agree with you that
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`CATSYNC is not required to transfer a file. I think an
`underlying question though is because Aytac talks about
`a preferred embodiment having the CATSYNC installed,
`why would a person of ordinary skill in the art take the
`teachings of Aytac, but exclude that driver and create the
`claimed invention?
`MR. PEARCE: So, Judge Bisk, I'm glad you
`asked that question, because that really is the patent
`owner's argument here and it's both a
`mischaracterization of our argument and the wrong
`question to ask really. The reason why is, the person
`skilled in the art does not have to exclude CATSYNC in
`our obviousness argument. CATSYNC or Aytac does
`not have to be modified to remove CATSYNC.
`So, if I go back to slide 40 when we have the
`patent owner's argument that our obviousness theory is
`based on an impermissible modification, that is not our
`obviousness theory. Our theory is not the one skilled in
`the art would read Aytac, remove CATSYNC and then
`have the claimed invention. Aytac, again with additional
`details, from the SCSI specification will fill in some of
`those gaps is the claimed inventions.
`Even with CATSYNC on there because
`CATSYNC is not required. Just like there are any
`number of other programs shown and disclosed in Aytac
`and just like you would expect in any other number of
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`programs on a computer. Aytac also talks about having
`the Windows fax
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