`Ian CrayfordIan Crayford
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`7/21/20177/21/2017
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`JUNIPER NETWORKS, INC., )U.S. Patent No.
` )8,942,107
` Petitioner, )Case IPR2016-01391
` )
` vs. )U.S. Patent No.
` )8,155,012
`CHRIMAR SYSTEMS, INC., )Case IPR2016-01389
` )
` Patent Owner. )U.S. Patent No.
`_____________________________________)8,902,760
` )Case IPR2016-01399
`RUCKUS WIRELESS, INC., BROCADE )
`COMMUNICATION SYSTEMS, INC., AND )U.S. Patent No.
`NETGEAR, INC., )8,942,107
` )Case IPR2017-00718
` )
` Petitioner, )U.S. Patent No.
` )8,155,012
` vs. )Case IPR2017-00790
` )
`CHRIMAR SYSTEMS, INC., )U.S. Patent No.
` )8,902,760
` Patent Owner. )Case IPR2017-00719
`_____________________________________)
`
` DEPOSITION OF IAN CRAYFORD
` Los Angeles, California
` Friday, July 21, 2017
` VOLUME I
`
`Reported by:
`RENEE D. ZEPEZAUER, RPR, CRR
`CSR No. 6275
`JOB No. 2663279
`
`PAGES 1 - 185
`
`CHRIMAR 2055
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`Ian CrayfordIan Crayford
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`Page 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`JUNIPER NETWORKS, INC., )U.S. Patent No.
` )8,942,107
` Petitioner, )Case IPR2016-01391
` )
` vs. )U.S. Patent No.
` )8,155,012
`CHRIMAR SYSTEMS, INC., )Case IPR2016-01389
` )
` Patent Owner. )U.S. Patent No.
`_____________________________________)8,902,760
` )Case IPR2016-01399
`RUCKUS WIRELESS, INC., BROCADE )
`COMMUNICATION SYSTEMS, INC., AND )U.S. Patent No.
`NETGEAR, INC., )8,942,107
` )Case IPR2017-00718
` )
` Petitioner, )U.S. Patent No.
` )8,155,012
` vs. )Case IPR2017-00790
` )
`CHRIMAR SYSTEMS, INC., )U.S. Patent No.
` )8,902,760
` Patent Owner. )Case IPR2017-00719
`_____________________________________)
`
` Deposition of IAN CRAYFORD, VOLUME
` I, taken on behalf of Patent Owner, at
` 1800 Avenue of the Stars, 9th Floor, Los
` Angeles, California, beginning at 9:09
` a.m. and ending at 5:17 p.m., Friday,
` July 21, 2017, before RENEE D.
` ZEPEZAUER, Certified Shorthand Reporter
` No. 6275.
`
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`APPEARANCES:
`
`For Petitioner:
` IRELL & MANELLA LLP
` BY: TALIN GORDNIA
` Attorney at Law
` 1800 Avenue of the Stars, 9th Floor
` Los Angeles, California 90067
` (310) 277-1010
` tgordnia@irell.com
`
`For the Patent Owner:
`
` BROOKS KUSHMAN PC
` BY: THOMAS LEWRY
` Attorney at Law
` 1000 Town Center, 22nd Floor
` Southfield, Michigan 48075
` (248) 226-2753
` tlewry@brookskushman.com
` (Video conference appearance.)
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`APPEARANCES (Continued):
`
`Page 4
`
`For Ruckus Wireless, Inc., Netgear, Inc., and Brocade
`Communication Systems:
` DUANE MORRIS LLP
` BY: CHRIS TYSON and
` MATT YUNGWIRTH
` Attorneys at Law
` 505 9th Street NW, Suite 1000
` Washington, D.C. 20004
` (202) 776-7851
` cjtyson@duanemorris.com
` myungwirth@duanemorris.com
` (Telephonic appearance.)
`
`Also Present:
` CHRISTOPHER SMITH, Brooks Kushman
` (Video conference appearance.)
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`Page 5
`
` INDEX
`WITNESS EXAMINATION
`IAN CRAYFORD
`Volume I
` BY MR. LEWRY 6, 181
` BY MS. GORDNIA 177
`
` EXHIBITS
`NUMBER DESCRIPTION PAGE
`Exhibit 1046-107 Second Declaration of Ian 33
` Crayford
`Exhibit 2050 IEEE Standards for Local & 35
` Metropolitan Area Networks
`Exhibit 1001-012 United States Patent 64
` 8,155,012 B2
`Exhibit 2054 EIA/TIA Bulletin 171
`
` PREVIOUSLY MARKED EXHIBITS
` NUMBER PAGE
` Exhibit 1003-107 13
` Exhibit 1032 31
` Exhibit 2041 87
` Exhibit 2042 90
` Exhibit 2045 91
` Exhibit 1008 98
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`Page 6
` Los Angeles, California, Friday, July 21, 2017
` 9:09 a.m.
`
` IAN CRAYFORD,
`having been administered an oath, was examined and
`testified as follows:
`
` EXAMINATION
`BY MR. LEWRY:
` Q Good to see you again, Mr. Crayford. How are
`you?
` A Good. How are you?
` Q I'm doing well, thank you.
` So for the record, I want to put everybody's
`appearances on, and so the record's clear we're doing a
`video deposition of you today. You're in the offices of
`Irell & Manella, I think, and I'm here in my offices in
`Southfield, Michigan. So here with me today is Chris
`Smith. And so we're the only two in the room today.
` So, Talin, if you're there, could you also do
`some appearances at your end?
` MS. GORDNIA: Sure. Talin Gordnia from Irell &
`Manella representing petitioner Juniper Networks and
`Mr. Crayford.
` And on the line with us, we have Matthew
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`Page 7
`Yungwirth and Chris Tyson of Duane Morris, representing
`petitioners Ruckus and Netgear, as well as Mr. Crayford.
` MR. LEWRY: All right. That's everybody?
` MS. GORDNIA: That's everybody.
`BY MR. LEWRY:
` Q All right. Excellent.
` So, Mr. Crayford, since the last time we met,
`there have been a few things that have happened, and the
`thing that brings us together again is that you have
`submitted some additional declarations in the four IPRs
`that are involved with respect to the ChriMar patents;
`is that right?
` A Yes, that's correct.
` Q And we're here today to discuss those
`declarations with you.
` And, Talin, I believe you have copies of some
`material that we had asked you to collect; is that fair?
` MS. GORDNIA: I do.
` And, Renee, I didn't get a real time monitor,
`if you have one for me. And if you don't, that's fine.
` (Discussion off the record.)
` MS. GORDNIA: Yes. I do have the documents
`that you asked us to print out.
` MR. LEWRY: Excellent. And we'll get to those
`in a minute.
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`Page 8
` Q So I want to start, Mr. Crayford, with some
`just definitions and understandings so we can make sure
`we're talking about the same thing and talking about the
`same issues.
` One of the terms I wanted to talk to you about
`is the term ISDN. You're familiar with that term?
` MS. GORDNIA: Objection. Form.
` THE WITNESS: I'm familiar with the term, yes,
`integrated -- yeah. Go ahead.
`BY MR. LEWRY:
` Q Integrated Services Digital Network is what it
`stands for?
` A Correct.
` Q Okay. An ISDN channel can carry voice, video,
`data; correct?
` MS. GORDNIA: Objection. Form.
` THE WITNESS: I mean it's capable. It depends
`on what type of services it offers, but the overarching
`ISDN set of specifications are intended to basically
`digitally replace the analog phone network.
` Q Right. So back in the -- I remember back in
`the late '80s and early '90s, ISDN was rolling out, it
`was something offered by the telephone companies as a
`replacement, as you say, for the analog network in a
`digital form; is that -- does that meet with your
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`Page 9
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`recollection?
` MS. GORDNIA: Objection to form and relevance.
` THE WITNESS: In general. I mean, I --
`certainly the phone companies were -- the traditional
`phone companies were producing ISDN equipment and
`rolling out in replacement of the analog phone, and
`obviously there were many other companies who built
`ISDN-compatible equipment that connected to a network.
`So I wouldn't say it was exclusively the domain of the
`phone companies. In general, I believe they started the
`rollout.
`BY MR. LEWRY:
` Q And before ISDN, if -- and you probably have
`memories of this too, when I wanted to hookup my
`computer to the telephone network, I had to use a modem,
`and it made all kind of funny sounds, and then I
`connected. The best-case scenario I could maybe connect
`at 56K baud or something like that; do you remember
`that?
` MS. GORDNIA: Objection to form. Foundation
`and relevance.
` THE WITNESS: I remember squawky modems, yes.
`BY MR. LEWRY:
` Q That was because over the analog network that
`was the way to connect from one end to the other using
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`Page 10
`
`computers; is that right?
` MS. GORDNIA: Objection to form. Foundation.
`As well as relevance.
` THE WITNESS: Well, certainly for a lot of home
`and small business -- small business, that was a way to
`get -- to get into the -- to get remote access to
`wherever they were going, whether that was remote access
`to, you know, a corporate headquarters or whatever, or
`whether that was the AOL, you've got mail.
` But there were obviously other things around.
`The ARPANET was being developed for many years. I mean,
`what I'm trying to say, it wasn't the exclusive
`mechanism to get connectivity remotely, but it was
`certainly something that was, I believe, clearly fairly
`popular in the -- certainly for home uses, yes.
`BY MR. LEWRY:
` Q And I'm not suggesting it was the exclusive, by
`any means.
` And then when ISDN came out, one of the things
`that they said about ISDN was it was a quicker way to
`connect as opposed to using the analog networks, you
`could use the ISDN and connect your computer up and
`communicate like you did with your old dial-up modems,
`but now you had a faster connection; wasn't that one of
`the things they talked about?
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`Page 11
` MS. GORDNIA: Objection to form. Relevance,
`scope, as well as foundation for the question.
` THE WITNESS: Certainly one of the promises was
`increased bandwidth. Yeah. I mean, I'm not convinced
`it was necessarily materialized in all cases because it
`depended on the -- there was a cost involved clearly,
`subscriber cost and -- so, anyway ...
`BY MR. LEWRY:
` Q You had to be able to afford it?
` A There was an intended promise that it would be
`the panacea of getting you away from analog modems and
`into the digital age.
` Q Okay. And are you familiar with the term BRI
`in the context of ISDN stands for Basic Rate Interface?
` MS. GORDNIA: Objection. Form. Scope.
`Relevance and foundation.
` THE WITNESS: Yes, I'm familiar with the term.
`BY MR. LEWRY:
` Q And there's also a term BRI in the patent world
`that stands for something completely different, but I
`want to focus -- you know, when I'm talking about BRI,
`unless I say otherwise, I'm talking about the BRI in the
`ISDN context. Okay?
` A Okay.
` Q And you understand that the ISDN had a B, B as
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`Page 12
`
`in boy, channel for data flow?
` MS. GORDNIA: Objection to form. Scope.
`Relevance. And foundation.
` THE WITNESS: Well, I mean, there was --
`there's multiple services offered in our ISDN. One of
`the more popular ones is what's generally referred to as
`2B+D, where it's two bearer channels, which is peculiar,
`because they are the bearers. They are actually the
`data channel, and the D channel is called the data
`channel, but it's actually the control channel. So
`but -- yeah.
`BY MR. LEWRY:
` Q Right. Okay. I was going to get to D channel
`next, but, yes, that's my understanding as well.
` And the way ISDN worked was it was a circuit
`switched system; correct?
` MS. GORDNIA: Objection to form. Scope.
`Relevance and foundation.
` THE WITNESS: The -- the phone companies
`traditionally had circuit switch networks, and the two
`domains in the world were the phone circuit switch
`networks and the local area network packet switch
`networks and never the twain shall meet.
`BY MR. LEWRY:
` Q Right.
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`Page 13
` Talin, if you could pull out Exhibit 1003-107
`that we marked last time. That's the Hunter
`specification.
` So, Mr. Crayford, you have in front of you now
`the Hunter specification which was marked at your last
`deposition as 1003-107. If you turn to page 10, and
`when I refer to the pages, I'll just refer to the page
`numbers at the top to avoid confusion.
` A Okay.
` Q And in Hunter there's a table on page 10 that
`basically confirms what you just told me, that there's
`packet networks, there's circuit networks, and Hunter
`also talks about the cell networks. Do you see that?
` MS. GORDNIA: Objection to form.
`Mischaracterizes testimony.
` THE WITNESS: Yeah, this is Hunter's summary
`of, as he says, different aspects of each of these
`transport services.
`BY MR. LEWRY:
` Q Right. And in the packet category in the row
`that's labeled "typical technology," it lists Ethernet
`with a circle R, Token Ring with a circle R, Frame Relay
`with a circle R, et cetera. Do you see that?
` A Yeah, I see that.
` Q And under "circuit" it lists ISDN and T1. Do
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`you see that?
` A Yes.
` Q And then under "cell" it lists asynchronous
`transfer mode (ATM); do you see that?
` A Yes, I see that.
` Q And in reading Hunter, do you recall that
`Hunter had the view that eventually the world was going
`to be run on ATM?
` MS. GORDNIA: Objection to form. And
`relevance.
` MR. LEWRY: You're right, Talin, it was a bad
`question.
` Q Do you recall that Hunter said that the network
`infrastructure, the private network infrastructure, was
`going to be ATM?
` MS. GORDNIA: Objection to form and relevance.
` THE WITNESS: I certainly remember Hunter has
`quite a long preamble of what's going to happen in the
`networking world and when ATM takes over the world.
`That was his -- I believe his philosophy.
`BY MR. LEWRY:
` Q Yeah. Right. And you'll find that, for
`example, on page 11, line -- starting at line 14, do you
`see that he says at some point it is expected the entire
`private network structure will employ ATM?
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` A Right. Yes. I see that.
` Q All right. So the other -- in the beginning of
`this, his specification, Hunter, has a number of the
`tables that's sort of setting the groundwork for what
`he's -- what his invention is; is that fair?
` MS. GORDNIA: Objection to form.
` THE WITNESS: I -- I mean, that would be --
`that may be one way to characterize it. I must admit, I
`was -- I have been -- it's a very long-winded preamble
`to get to phantom powering.
`BY MR. LEWRY:
` Q And then if you go to page 15 in Hunter,
`there's a paragraph that starts on line 2, and he says,
`"There are certain existing communication technologies
`that must be supported and others that are used."
` Do you see that?
` A Yes, I see that.
` Q Right. And then he says, the next sentence, "A
`truly interoperable interactive multimedia system shall
`guarantee that the physical and logical interfaces of
`each component adheres to a standard." Do you see that?
` A Yes, I can see that.
` Q And then he continues on, and you can --
`certainly are welcome to read it, but what I want to get
`to is the table that's down below that paragraph that's
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`Page 16
`labeled Table 7, Roman numeral VII, interoperability
`standards. And then he's got a table with three columns
`and four rows, and one of the rows is labeled
`isoEthernet circle R (IEEE 802.9a.) Do you see that?
` A Yes, I see it.
` Q And then the next column over the -- identified
`signaling standards that he associates with isoEthernet
`is ISDN NI-2. Do you see that?
` A Yeah. I can see it, yes.
` Q Okay. And then the next column is compression
`standards and so forth. All right. So is it -- so
`reading this, do you understand that when Hunter is
`talking about isoEthernet and 802.9a, he's talking about
`ISDN signaling?
` MS. GORDNIA: Objection to form and scope.
` THE WITNESS: No. I don't. IsoEthernet -- I'm
`trying to couch my answer correctly.
` So isoEthernet incorporates both -- let me
`backtrack again. I'm sorry.
` The only practical deployment of isoEthernet
`was a version that incorporated 10Base-T and ISDN. It
`wasn't highly successful in the marketplace, but it was,
`as far as I'm aware, the only real commercial deployment
`that was made.
` So 802.9 was intended generically to allow an
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`Page 17
`802.x LAN service, so it could be Token Ring, could be
`Ethernet, could be token bus, could be any of the .3, 4,
`5 up to 6, it could be any of those standards.
`Presumably it wouldn't be wireless, but that signal,
`wired standards, it was intended to allow that to
`coexist with an isochronous channel, which was the ISDN
`channel.
` The two channels basically are stand-alone in
`their own rights so ISDN can do its signaling in the
`case of the fundamentally only successful deployment
`that was made.
` The Ethernet did its signaling. The
`Ethernet -- and then it got channeled into what was
`called a hybrid marks, which was a physical layered
`device, which actually did most of the work, and it took
`those two disparate packet switch and circuit switch
`networks and sort of forced them into one pipe, which
`was a wire, and it did that by some encoding.
` So when you say isoEthernet only does ISDN
`signaling, I can't agree with that comment.
` IsoEthernet has its own signaling, and the
`signaling across the wire is a 4B5B encoding with NRZI,
`which is non return to zero inverted.
` So that's the signaling that was in the
`deployment in the -- let me use a term, if it's
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`convenient for us. When I say the only successful
`version of isoEthernet, basically National
`Semiconductor, Nat Semi or NSC, were the proponents of
`that and did the chips for it and were really the only
`people who fundamentally supported it in the standards.
`They gave that version of the standard to the standards
`body, and they adopted it as kind of the only working
`version of 802.9 that kind of actually did stuff.
` So the 802.9 standard actually we've been
`looking at, and he's referenced, Hunter references that
`particular -- I mean, he's talking about that version of
`isoEthernet. IsoEthernet is a national trademark, I
`believe. I'm not 100 percent sure, but I believe so.
` So when we're talking about isoEthernet, we're
`talking about 10Base-T and ISDN next to each other, over
`the same wire and with different modes of operation
`supported, which allows either stand-alone Ethernet
`connection, a stand-alone ISDN connection, and then
`layers of both of those -- actually both of those to
`co-exist with ISDN having additional layer capabilities.
`So it has, you know, more and more bandwidth, different
`services for the isochronous so you can support video
`conferencing.
` Sorry. That was a really long-winded answer to
`your question.
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`BY MR. LEWRY:
` Q That's all right. I don't mind. So if we go
`back to -- let me start again.
` One of the terms you used I think in your
`answer, and also I've seen it in your declarations, is
`10Base-T mode. That's a phrase you're familiar with;
`right?
` MS. GORDNIA: Objection. Form.
` THE WITNESS: Yes.
`BY MR. LEWRY:
` Q In this context. And in your declaration you
`said that the 802.9a standard included a 10Base-T mode
`in addition to the ISDN mode; right?
` MS. GORDNIA: Objection to form and foundation
`of the question.
` THE WITNESS: Could you read that back, please.
` (Record read.)
` MS. GORDNIA: Objection to form. Foundation.
`Which declaration? You said just declaration; right?
` MR. LEWRY: Talking about your latest
`declaration, declaration No. 2, the one that's dated
`July 7th, I believe, of this year. Yes.
` MS. GORDNIA: Tom, I have all of those printed,
`all four, as well.
` THE WITNESS: It would really help if I had one
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`of the declarations so I could look at specifically
`where I'm talking about, if that's okay.
` MR. LEWRY: Okay.
` Q But before we get there, I just want to confirm
`that I think you gave it in your answer just a minute
`ago too, you said that there was a 10Base-T mode that
`was part of the IEEE 802.9a standard and that was in
`addition to the ISDN modes.
` Did I understand that wrong?
` MS. GORDNIA: Objection to form.
` THE WITNESS: Yeah. You know, I was trying to
`make the distinction so the National Semiconductor
`implementation is -- is that implementation of 10Base-T
`and ISDN that co-exist with each together. That's the
`isoEthernet.
` 802.9a, I'm -- I don't want to be held
`completely 100 percent accountable to this, but I don't
`think it ever references isoEthernet. That was an
`implementation. So the iso was isochronous. The
`Ethernet was Ethernet. I believe National, as I said,
`was the trademark holder of that.
` So I think if we look at 802.9a, it will be
`very generic, and it says -- and that's the point I was
`trying to make. It says you can have a LAN service and
`an ISDN service and various complexities of ISDN
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`service, and any one of those is optional.
` The LAN service is not specified as 10Base-T in
`802.9a. That's a function of the implementation that
`was produced in the marketplace, where they said the
`802.x is going to be 802.3 10Base-T.
`BY MR. LEWRY:
` Q Okay. You mentioned a couple times this NSC
`specification. Is that in the record anywhere?
` MS. GORDNIA: Objection. Form.
`BY MR. LEWRY:
` Q That we have.
` A The very large book that we looked at
`previously which I thought -- think is called "Maximum
`Bandwidth" has a chapter on isoEthernet and, for
`instance, it mentions these particular modes. It
`doesn't mention all of the modes, but it mentions some
`of the modes.
` And I think -- I'm not 100 percent, but I
`believe that is focused on only the National
`Semiconductor version, the isoEthernet version, the
`chapter is called isoEthernet. So I'm reasonably
`certain it's not talking about the generic 802.9a. It's
`talking about this is isoEthernet. It has ISDN. It has
`10Base-T. It has some other things about it.
` I don't think it -- I don't know if it grants
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`the credit to National or not. I believe it's
`fundamentally talking about isoEthernet. So to that
`extent, there's something about isoEthernet in the
`record.
` Q And you believe that at the time Hunter did his
`patent application, Exhibit 1003-107, that he would have
`known about the 10Base-T mode that you've described?
` MS. GORDNIA: Objection to form.
` THE WITNESS: I do.
`BY MR. LEWRY:
` Q So isn't it significant to you that on page 15
`when he identifies isoEthernet 802.9a he doesn't mention
`the 10Base-T mode and Ethernet switching as a signaling
`standard?
` MS. GORDNIA: Objection to form.
` THE WITNESS: I believe this table in the page
`15 where you previously pointed me to, I think it starts
`on line 3, that chapter is -- that paragraph is really
`talking about interactive multimedia system.
` So, for instance, "The present day affords the
`opportunity to evolve the proprietary telephony of the
`PBX and the proprietary video of the video-conferencing
`systems" -- excuse me -- "into standards-based systems
`in the same manner that data systems evolved from
`proprietary mainframes to the standard-based LANs."
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` I believe he's talking here about multimedia
`systems and most people at -- well, first off, given his
`bent the ATM is going to rule the world, this guy is a
`circuit switch and packet switch guy primarily. And so
`he's talking here about circuit switch and packet
`switch, and he's not specifically addressing the LAN
`piece. The LAN -- nevertheless, the LAN piece is there,
`and I believe he makes use of it.
`BY MR. LEWRY:
` Q Well, the sentence right above the table says,
`"The following Table VII summarizes the required
`standards of interoperability." And in the previous
`sentence he mentioned, as you said, the video and so
`forth, but he also mentioned standard-based LAN in that
`sentence. Wouldn't you expect he's identifying all the
`different types of standards that he needs to have
`operability with in his invention?
` MS. GORDNIA: Objection to form and scope.
` THE WITNESS: Well, in this particular table
`he's referring to signaling standards. And the -- the
`same signaling standards -- these are the signaling
`standards -- you have to have a signaling standard to
`make one of these works. They don't work otherwise.
`LANs work without a set signaling standard.
`//
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`BY MR. LEWRY:
` Q Okay. So you're thinking he just didn't think
`he needed to mention 10Base-T mode of isoEthernet?
` MS. GORDNIA: Objection to form. Scope and
`foundation.
` THE WITNESS: Well, on the following page, for
`instance, on 16, starting at around line 7, he says,
`"The draft standard 802.9a provides for the integration
`of" voice -- sorry, "video, voice, and data services to
`a desktop computer system."
` I believe some of the data services he's
`referring to are very specifically Ethernet data
`services. So I -- so he's saying next sentence, "A
`needed step in the evolution of this integration is to
`provide for a level of service equal to or greater than
`currently available from a LAN, PBX, and WAN systems."
` So he's trying to implement a system that
`incorporates the benefits of each of those elements, and
`that includes a 10Base-T element and an ISDN or
`isochronous element.
`BY MR. LEWRY:
` Q But you told me earlier that ISDN can handle
`all three of those things, video, voice, and data
`services to a desktop computer system; right? So it
`could just be ISDN; right?
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` MS. GORDNIA: Objection. Form.
`Mischaracterizes testimony.
` THE WITNESS: I think I said that there's --
`there's at least three modes. There's a packet mode
`which is -- in the isoEthernet, it's 802.3 10-Base-T
`mode. There's an ISDN only mode. There's a hybrid
`mode. Each is supported.
`BY MR. LEWRY:
` Q I'm not talking about isoEthernet now. Just
`ISDN alone. ISDN alone can handle voice, video, and
`data services to a desktop computer; right?
` MS. GORDNIA: Objection to form.
`Mischaracterizes testimony.
` THE WITNESS: Yes. It's fair to say that ISDN
`has the capability to have a data service. It doesn't
`have -- even at the provision that's made in
`isoEthernet, the ISDN data service's still substantially
`lower than the Ethernet data service.
`BY MR. LEWRY:
` Q Lower in speed, you mean?
` MS. GORDNIA: Objection to form.
` THE WITNESS: Lower in bandwidth.
`BY MR. LEWRY:
` Q Okay. Now, do you believe Hunter's system
`would supply enough phantom power to power a desktop
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`computer system?
` MS. GORDNIA: Objection to form and foundation.
`And scope.
` THE WITNESS: Do I -- I don't think he ever
`makes the assertion that he's trying to power a desktop
`PC. He -- he makes the assertion that he's --
`BY MR. LEWRY:
` Q Go ahead.
` A I apologize.
` MR. YUNGWIRTH: Tom, you need to let him finish
`his answer.
` MR. LEWRY: I know. I think there's a little
`bit of a delay between us and so I think that's causing
`me to jump in when I think he's done. So I apologize.
`You were finishing your answer.
` MS. GORDNIA: Sorry. Can you repeat the
`question?
` MR. LEWRY: Let me just reask.
` Q You understand that Hunter's goal was to be
`able to power voice instruments, like phones, if there
`was a power failure using the phantom power; right?
` MS. GORDNIA: Objection to form and scope.
` THE WITNESS: I believe that is one of his
`stated objectives, in the event that local power is not
`available to a phone that's hooked to a PC, which would
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`be hooked in his case through his ISTE card that's
`resident inside the PC, that phone would continue to
`operate if the PC were either powered down itself or the
`power supply in the -- let's say the building or the
`local area was not operational. That was an intended --
`I believe that's certainly an intention that he
`disclosed.
`BY MR. LEWRY:
` Q And you don't know anywhere in the Hunter spec
`where he disclosed an intention to power a desktop
`computer system, do you?
` MS. GORDNIA: Objection
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