Paper 79
`Entered: April 2, 2014
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`RECORD OF ORAL HEARING
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.
`Petitioner
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`v.
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`ACHATES REFERENCE PUBLISHING, INC.
`Patent Owner
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`
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`Oral Hearing Held: February 26, 2014
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`Before HOWARD B. BLANKENSHIP, JUSTIN T. ARBES, and GREGG
`I. ANDERSON, Administrative Patent Judges.
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER:
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`JEFFREY P. KUSHAN, ESQUIRE
`JOSEPH A. MICALLEF, ESQUIRE
`Sidley Austin, LLP
`1501 K Street, N.W.
`Washington, D.C. 20005
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`ON BEHALF OF THE PATENT OWNER:
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`VINCENT E. McGEARY, ESQUIRE
`Gibbons, P.C.
`One Gateway Center
`Newark, New Jersey 07102-5310
`BRAD D. PEDERSEN, ESQUIRE
`Patterson, Thuente, Pedersen, P.A.
`4800 IDS Center, 80 South 8th Street
`Minneapolis, Minnesota 55402
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`The above-entitled matter came on for hearing on Wednesday,
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`February 26, 2014, commencing at 2:11 p.m., at the U.S. Patent and
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`Trademark Office, 600 Dulany Street, Alexandria, Virginia 22314.
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`P R O C E E D I N G S
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`- - - - -
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`JUDGE ARBES: This is the oral hearing in two cases, Cases IPR
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`2013-80 and 2013-81 involving Patent 6,173,403 and Patent 5,982,889.
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`Would counsel please state your names for the record?
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`MR. KUSHAN: Jeff Kushan and Joe Micallef for Petitioner Apple.
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`MR. PEDERSEN: Brad Pedersen and Vincent McGeary for the
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`Patent Owner Achates.
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`JUDGE ARBES: Per the Board's trial hearing order in these cases,
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`each party will have 90 minutes total time to present for the two cases. You
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`can allocate that time however you would like. The order of presentation
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`will be that counsel for the Petitioner will go first regarding the challenged
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`claims in the 80 case. You may reserve time for rebuttal.
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`The Patent Owner will then respond with respect to the challenged
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`claims in the 80 case. The Petitioner can then use rebuttal time for that one.
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`We will then take a short break and then proceed in the exact same manner
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`for the 81 case.
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`A couple of reminders before we begin, to ensure that the transcript is
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`clear, because we have one judge in the Denver office, we would ask the
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`parties to please try to remember to refer to your demonstratives by slide
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`number so the record is complete. And, also, if you can stay near the
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`podium so that the judge in the other office can hear you.
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`Do the parties have copies of the demonstratives that you will be
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`using today?
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`MR. KUSHAN: Yes, Your Honor. May I approach?
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`JUDGE ARBES: Yes, please.
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`MR. KUSHAN: These are the demonstratives. I also was going to
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`ask that we provide you with a copy of the one exhibit that's under seal so
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`you have it accessible. If that's okay, I can leave it with you. These are our
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`copies for the panel.
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`MR. McGEARY: Your Honor, we don't have an extra copy of the
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`demonstrative exhibits.
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`JUDGE ARBES: That's fine. Counsel for the Petitioner, you can go
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`first. And would you like to reserve time for rebuttal? And, if so, how
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`much?
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`MR. KUSHAN: We would like to reserve about half of our time for
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`rebuttal. And we will take it somewhat as we go to the second proceeding.
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`Thank you very much. Today's hearing is going to focus on two
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`patents in a fairly crowded field of technology with a fair amount of prior
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`art. And before we get into the details, it is important to appreciate that the
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`patents that we are dealing with concern a technique, which essentially takes
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`a set of information and uses a conventional encryption technique as an aid
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`to transfer the files securely.
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`When you look at the patents, they employ very well in very
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`established encryption and other techniques that have been in the prior art
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`for a fair amount of time. And as we go through the issues, you will see that
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`the claims are, in fact, going to be fairly, clearly obvious or anticipated by
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`that prior art.
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`So we move to Slide 2. These are the grounds that we are going to be
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`addressing. And I am also going to be taking up the grounds based on Pettitt
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`and Beetcher. And my colleague Mr. Micallef will be taking up the grounds
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`based on Ginter. If we go to Slide 3.
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`The first issue I would like to address is the finding of anticipation by
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`Pettitt. This is Claim 1. It has been found anticipated. And what we did in
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`our petition was outline that there were two distinct authentication codes in
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`the Pettitt scheme. And if you see on the bottom here in our '403 petition at
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`Pages 26 and 27, we explain how the Pettitt scheme works.
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`In Pettitt, there is an encrypted reply envelope, which is created.
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`Inside that encrypted reply envelope are a number of items and information.
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`One of them is called the digital authorization certificate. I will call that the
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`DAC for short. In the process, this encrypted reply envelope is sent through
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`a chain down to a reseller. And then when the reseller receives that, it
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`decrypts it and recovers the information inside the envelope.
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`The encrypted reply envelope is also signed with the digital signature
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`of the LCH, license clearinghouse. Once it's decrypted at the reseller, the
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`contents are then passed on to the user. And those contents, including the
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`DAC, are used to install the software.
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`This demonstration in Pettitt -- as I said, this is from our petition. We
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`have very clearly identified that there were actually two authentication codes
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`in the Pettitt scheme. One was the LCH digital signature. And if we go to
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`Slide 8, this is one of the statement of facts we included with our petition in
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`81 where we set out our position with the digital authorization certificate as
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`an authentication code supported by evidence of Mr. Schneier.
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`JUDGE ARBES: What's your position on Pettitt regarding the
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`assertions in the petition in the 80 case? It seems to have to do a lot with the
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`assertion in the body of the petition that the LCH's digital signature is the
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`first candidate authentication code. That's what's referred to on Page 27 of
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`the petition. And while this was in the statement of facts, it is not in the
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`body of the petition itself. Can you address that?
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`MR. KUSHAN: Well, if I could go back to Slide 3. This passage is
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`actually from our petition proffer. And the way we organized our petition
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`was to outline a number of material facts that we felt were going to
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`demonstrate the evidence constituting anticipation or obviousness of the
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`patent claims. And then we relied on the statement of facts as well as our
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`explanations of how the scheme worked to demonstrate the evidence that is
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`making out the case for anticipation.
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`So we feel like we clearly conveyed that there were two
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`authentication codes being distributed in the scheme. And I also would note
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`that I think that was fairly communicated because the Patent Owner in its
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`opposition -- first of all, it is stated in one of its oppositions. We can go to
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`Slide 76. This is in the '889 proceeding. This is them responding to our
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`position in their opposition. And you can see number two is the DAC.
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`And if you go to Slide 6. When they responded to the '403 patent,
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`what they did was identified a passage that we extensively discussed, both in
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`our petition and in our expert report. And you can see they are quoting this
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`passage where it is showing what's inside the reply envelope. And, again,
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`this is a particular passage we discussed demonstrating that there is another
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`authentication code inside the reply envelope.
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`JUDGE ARBES: So is it the Petitioner's position, then, that both are
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`the first candidate authentication code? Digital authorization certificate and
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`the LCH digital signature.
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`MR. KUSHAN: Yes.
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`JUDGE ARBES: What is the argument, then, and what is your
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`position as to why the LCH digital signature is the first candidate
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`authentication code?
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`MR. KUSHAN: Sure. So the LCH digital signature -- first of all, a
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`digital signature is an authentication code as the Patent Owner has contended
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`that term is to be construed. And what we pointed out in our petition was
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`that with respect to the LCH digital signature, that is decrypted to recover
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`the information. It is actually appended to the reply envelope and sent along
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`with it. And through this action of transfer and decryption and unpacking of
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`that reply envelope, you recover that authentication code, which is the digital
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`signature. And then you are going to use that to verify that the message that
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`it accompanies is authentic in the reply envelope.
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`JUDGE ARBES: It is not part of the reply envelope itself, though, is
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`it?
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`MR. KUSHAN: I think it is intended. It is used to sign the encrypted
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`reply envelope. So it is transferred with the data set that is the reply. So it is
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`not disassociated from it.
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`JUDGE ARBES: How do we know that from the reference?
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`MR. KUSHAN: Well, that's essentially how digital signatures work.
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`You take -- and, in fact, if you go to the -- we didn't provide you with a
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`demonstrative about this. But in the Pettitt scheme, it explains that the LCH
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`digital signature is bundled with the reply envelope and transferred. And
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`then when that entire data set comes to the reseller, the reseller takes the
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`digital signature and verifies that the encrypted reply envelope is authentic.
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`So it is moving and carrying along with the data that is the encrypted reply
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`envelope. And we can -- I think we outlined that in more detail in our
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`papers, but we can drill down, if you wish.
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`But I think at the bottom, what we see is that we put out a very clear
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`position, I think, in our papers that the DAC is an authentication code inside
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`the reply envelope. In their opposition in one of the proceedings, they take
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`issue with that. And in the other proceeding, this one with '403, they didn't.
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`So you can readily find on the basis of your finding of anticipation that the
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`authentication code is the DAC. It is meeting the requirements of
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`anticipation of Claim 1, which is the ground you instituted on over Pettitt.
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`If we can go to Slide 9. And, again, we feel like it has been fairly
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`clearly understood by the Petitioner and by the Patent Owner that the digital
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`authorization certificate is an authentication code in Pettitt. One of the
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`issues we did address in Wang's declaration was whether he viewed a DAC
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`to be a digital signature. And he answered yes. And then he confirmed that
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`a digital signature inherently will function to authenticate data, which meets
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`the requirement for an authentication code.
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`Now, in the recent production of e-mails, we actually were able to see
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`that Dr. Wang didn't really seriously contest the idea that a digital
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`authorization certificate is an authentication code. And I direct you to
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`Exhibit 1067. This is under seal. So that's in the handout I gave you. The
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`quote that we pointed you to in the observations is him recognizing that the
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`idea that the digital authorization certificate is not an authentication is not
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`really a viable argument.
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`So I would like to move on to the next ground. Go to Slide 11. The
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`next issue was that the Board found that Claims 2, 4, 5, 7, and 9 are obvious,
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`based on Pettitt and Beetcher. And in this finding, the Board recognized that
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`it would have been obvious to modify the Pettitt scheme, which is if the
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`Board found distributes a single product, to distribute multiple products.
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`And the Board's finding relied on testimony from Mr. Schneier and
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`from the arguments we presented in our petition that you could adapt the
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`Pettitt scheme to distribute multiple products. And the combination of
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`Pettitt with Beetcher was the basis for this.
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`If you go to Slide 12, this is some of the reasoning that Mr. Schneier
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`provided as to why a person of skill would have considered it obvious to
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`modify Pettitt to distribute multiple products. He is pointing out that you
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`can just adapt it to use over multiple indicia.
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`Now, importantly, the Patent Owner didn't challenge Mr. Schneier's
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`testimony at his deposition. And so as you sit and review the evidence, this
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`is evidence that is supporting the original finding of obviousness, which
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`really hasn't been disputed.
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`Dr. Wang, when he put in his declaration, he provided -- he kind of
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`addressed a different question about where there is another reason why a
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`person of skill would combine the Pettitt and Beetcher schemes. If you can
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`go to Slide 13. This is a quote out of his declaration, Exhibit 2014. And
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`with the way we look at this, he is basically confirming that there is a
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`different reason why a person would combine Pettitt and Beetcher. And he
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`is pointing out that a person would recognize Pettitt has a problem. It
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`doesn't prevent illegal copying once the software has been installed. And
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`then he is pointing out that Beetcher solves that problem.
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`And the second thing he does with this observation, he confirms that it
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`is no big deal. It's no technical impediment to integrating the two schemes
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`so they can work together. So that's what I have to say about the second
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`ground.
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`The next ground, Slide 22, this was a finding that Claim 17 and 19 are
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`anticipated by Beetcher. And in their opposition, the Patent Owner really
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`only challenged one aspect of the Board's finding of anticipation. And that
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`was this one section I have highlighted in red. It's the element of Claim 17
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`that says the token is encrypted with the string before it is stored.
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`And essentially the Patent Owner and its expert failed to appreciate
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`that the teaching in Beetcher is that the product key table, which is the
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`element that we have pointed to as anticipating, is something called an
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`encoded product key table.
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`If you go to Slide 26, at the top of the page, this is an excerpt from
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`Dr. Wang's deposition. He is acknowledging that he didn't pay attention to
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`the name encoded in the sentence that says, "It is an encoded product key
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`table." And this is important because the Patent Owner's position is that our
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`argument was that storing an unencoded product key table was what we
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`were arguing met the requirement of the claim. We didn't argue that. We
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`argued that the encoded product key table is an encrypted product. And we
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`reached that conclusion by our analysis of our expert, Mr. Schneier, who
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`pointed out that Beetcher uses the word encoded and encrypted
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`interchangeably to mean the same thing.
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`So I asked their witness Dr. Wang about how he read Beetcher. And
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`he agreed that Beetcher uses these terms interchangeably. And so when our
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`expert looked at the Beetcher reference and saw the encoded product key
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`description, he read that as the encrypted product key table. And so under
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`the theory of what the claim requires, encrypting that product key table
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`satisfies the element of an encrypted token.
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`This was the only ground and the only theory they advanced to refute
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`the finding of the Board of anticipation of Claims 17 and 19. We just think
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`that the evidence from their witness on cross-examination demonstrates that
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`we met our burden for showing it was anticipated.
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`The next topic I would like to address -- go to Slide 27. This is a
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`finding that Claims 1 through 12 were obvious, based on Beetcher and two
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`different references. And what the Board found here, it found two
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`distinctions from the Claims 1 through 12 relative to Beetcher. One was that
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`the entitlement key in the Beetcher scheme, the Board found was not an
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`authentication code. And what it did was it looked at another reference,
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`Ginter, and found that Ginter provided the idea of modifying the entitlement
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`key with a digital signature.
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`If you can go to Slide 30. Actually, go to 29. So the first theory that
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`the Patent Owner advances to respond to this issue of integrating the digital
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`signature into the entitlement key was that basically an argument that Ginter
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`doesn't show that you recover the PERC, which is an analogous element in
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`Ginter, from an encrypted delivery mechanism or item. And they argued
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`that that meant that you should combine Ginter with Beetcher.
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`And what we observed is that their theory that the PERC is not
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`recovered by encryption is actually refuted by the actual text of Ginter. And
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`this is in Exhibit 1005 at paper 67. And if you look at the item 2843, that's
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`the step where the traveling object comes in decrypted from it is the
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`recovery of the PERC. So we think the first theory they advance that it is
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`not showing recovery of the PERC by decryption is simply refuted by the
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`evidence that is relied on.
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`The second theory that they advanced -- if you go to Page 30 or Slide
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`30. This is an excerpt from their opposition in the '403 case.
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`JUDGE ARBES: I'm sorry. Counsel, can we go back to the exhibit
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`before that? Why would a person of ordinary skill in the art substitute the
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`entitlement key feature or substitute in the digital signature as taught by
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`Ginter? What's the reason why a person of ordinary skill in the art would
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`want to do that?
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`MR. KUSHAN: It is to improve the security of the scheme. Digital
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`signatures were widely used in 1997. When our expert looked at the
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`Beetcher scheme, they saw a very analogous use of a digital signature to
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`enhance the security of a token or third element that's functioning to be a
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`verification mechanism. And he said, well, that would have been obvious to
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`improve that by using a digital signature.
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`JUDGE ARBES: And given how the authentication code is used in
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`the claim as part of a launch code, why would a digital signature be useful in
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`that particular scenario?
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`MR. KUSHAN: Well, and we have expanded again on our papers a
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`number of different reasons that Mr. Schneier found this to be obvious.
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`Again, part of it is that when you are using a system that's designed to
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`securely transfer into a verification mechanism data that you are using to be
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`the value that you are checking, it can always be improved by different
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`techniques. And one very common technique was the digital signature.
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`The other finding he made was that it would be really insignificant to
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`add that level of security into the Beetcher scheme. It doesn't really disrupt
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`how it works. It is not adding a lot of data into the scheme. So it can be
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`captured and integrated relatively easily.
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`And we will get into this and add that topic as somewhat engaged by
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`the next slide, Slide 30. In their opposition, the Patent Owner advanced this
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`theory. This is a theory that they argued, which is corresponding in
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`Dr. Wang's declaration. But, basically, they argued that a person wouldn't
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`have integrated a digital signature into the Beetcher scheme because adding
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`that digital signature data into the entitlement key would make it impractical.
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`And the reason they found it impractical is that they said, well, if you look at
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`Beetcher, it is envisioning essentially about a 16-character ASCII string.
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`That's their hypothetical. They felt that that would be reasonable to read
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`over the phone to a user and have the user type that in as part of the
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`installation process.
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`But then they drew a contrast. And they said if you added a digital
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`signature to the entitlement key, it would double or triple the size of that
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`entitlement key. And what that means is that it's going from 16 to 32 or 48
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`characters would cross some line that makes it unobvious. Now, when we --
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`this was supported by evidence from their expert Dr. Wang. So we took up
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`the issue of this hypothetical with Dr. Wang in his deposition.
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`If you can go to Slide 31, this is kind of the conclusion of the
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`discussion. We presented him with the example of the Windows XP
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`installer. And there is a telephone activation process in the Windows XP
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`installer program. Under that sequence, he walked through the steps and
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`confirmed them during his deposition. In that sequence, the user can in one
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`scenario be required to hear 42 digits read to them over the phone and type
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`in 42 digits into the Windows XP installer to authenticate. And he
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`confirmed that's what happens in that sequence. And then he also confirmed
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`Windows XP is one of the world's most widely used software products on
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`the planet. And it has been installed more than a billion times.
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`And, basically, we look at that time and conclude in their theory that
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`going from 16 to 32 characters would not be viable and essentially refuted
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`by the experience of Windows XP.
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`JUDGE ARBES: How do you address that? Where in the papers do
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`they acknowledge that Windows XP was 2001? How do you account for the
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`time difference? We are talking about 1997.
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`MR. KUSHAN: Right. So the theory you see them advance isn't
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`really something that's going to turn on a user's perspective in 1997 versus
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`2001. The theory they are advancing is that there is too many characters to
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`type in. They are basically saying 16 is okay; 32 is too many. And that's not
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`something that would make any sense to delineate between 1997 and 2001.
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`People didn't become familiar or accommodating with a greater
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`number of characters between those two dates. So the premise of their
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`argument is that it is just too many characters to type in if you go past 16.
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`And so we think that Windows XP testimony, which we are not offering as
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`prior art, we are offering it up as just refuting of the theory that they are
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`advancing that it's too many characters to type in.
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`JUDGE ARBES: If you were to substitute in a digital signature into
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`the system of Beetcher, how would a person type that into the computer?
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`Beetcher obviously is, according to the patent, it is 16 characters that they
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`type into the computer. A digital signature wouldn't operate the same way,
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`right? You just type in a set of characters.
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`MR. KUSHAN: It would. I mean, we went through the hypothetical
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`in some detail with Dr. Wang. And I can pull up his deposition transcript, if
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`you wish. But what we demonstrated through the cross-examination of
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`Dr. Wang is that if you took a 128-bit digital signature, that would add 16
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`characters to the string that's already there, which is 16 characters from the
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`entitlement key. And that ends up being 32 characters. And that's the basic
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`level of a digital signature -- 128 bits. And he confirmed my math, which
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`was very important. But we basically were taking their hypothetical and
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`used that 128-bit example to show that would be integration of a digital
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`signature.
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`JUDGE ARBES: And that could be done in ASCII or you could just
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`type that into the computer?
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`MR. KUSHAN: Yes. The last thing I am going to touch on before I
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`turn it over to Mr. Micallef is a second difference that we found relative to
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`Beetcher. If you can go to Slide 32. And, basically, the Board found that in
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`the Beetcher scheme, the entitlement key is checked essentially at runtime
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`after the software has been copied over. And we, in consultation with our
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`expert, found that it would have been obvious to modify that scheme to
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`essentially check the entitlement key as you are installing the software
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`instead of checking it after it has been loaded onto a computer. This is
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`something we set out pretty clear at Page 26 of our petition.
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`And that was supported by a number of paragraphs of Mr. Schneier's
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`declaration. And I have quoted 367 here. But, basically, the upshot is that a
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`person of skill from the perspective of Mr. Schneier would have considered
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`it obvious to modify the Beetcher scheme to capture the entitlement key and
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`to basically change the design of when it is checked so as to do that while
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`you are installing the software.
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`Again, this testimony from Mr. Schneier and this theory that we
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`advanced really wasn't tested at his deposition. And what we see in their
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`opposition essentially is kind of a theory that rests on, I think, a weak legal
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`foundation. Their arguments are essentially Beetcher works fine; we don't
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`need to modify Beetcher. So a person of skill wouldn't have any motivation
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`to change the Beetcher design.
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`For example, to install or check the entitlement key during the
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`installation process. And we think that really rests on the theory that has
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`been refuted by recent case law on obviousness. I think the standard that
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`you would say if you have to define a specific motivation to amend or
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`change the system, that's really not a viable basis for making the argument
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`for non-obviousness when you find another reason to adapt a system.
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`

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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`And from the testimony of Mr. Schneier, he is identifying this is
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`basically a simple design change. You would just enter the entitlement key
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`at a certain point earlier in the sequence.
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`JUDGE ARBES: Counsel, doesn't Beetcher really have nothing to do
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`with the installation of the software? I understand that Beetcher sends a
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`generic CD out to everyone. And how they install it doesn't matter to the
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`system that they are concerned about. So why would a person of ordinary
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`skill in the art modify that for the installation?
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`MR. KUSHAN: Well, Beetcher obviously does the check at runtime.
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`And that's one of the values of the Beetcher system. But when the person
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`looks at the prior art and thinks openly about whether you could adapt it to
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`relatively simply design changes, what immediately comes to mind is
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`another alternative. You capture the entitlement at the point of installation.
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`You have to get the entitlement into the scheme in Beetcher somehow. And
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`you can easily do that through the step or you are installing it.
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`You have the software on media. And it has to go from media to your
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`hard drive before you can use it. And you could either capture the
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`entitlement at that point when you are transferring during the installation
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`process, which is illustrated in the technique of Bohannon, or you can do it
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`at a later point in time. And our expert believed that kind of design choice
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`was relatively simple and obvious.
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`So we think on these grounds, the evidence really hasn't been
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`seriously disputed that supports the finding of unpatentability. I would like
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`to turn over the podium to my colleague Mr. Micallef to take over on the
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`Ginter issue unless you have any other questions.
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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`JUDGE ANDERSON: Counsel, before you do that, I would like to
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`follow up on this issue about the DAC.
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`MR. KUSHAN: Sure.
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`JUDGE ANDERSON: The claim says, "Encrypt the launch code with
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`a string to recover a first candidate authentication code." And so looking at
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`the claim language specifically, what's your evidence that the DAC is
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`recovered as a result of decrypting the launch code?
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`MR. KUSHAN: So can you go to Slide 3? So in the Pettitt scheme,
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`there are a number of data elements that are kind of taken together and
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`encrypted as a set. And that becomes the encrypted reply envelope. The
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`DAC is one of those data elements that's inside that encrypted rely envelope.
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`That encrypted rely envelope is then sent down to a reseller. And you go
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`through a distributor and directly to the reseller. And when the reseller gets
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`the encrypted replay envelope, it will decrypt the reply envelope and the
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`recovery contents. So now the contents are in unencrypted form as those
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`same data elements. Those data elements and then passed to the user and
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`used to install the software. And in Pettitt directly, it cites to DAC and the
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`master key for encrypting the software container to do that installation.
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`JUDGE ANDERSON: And where is that in your evidence? Is that in
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`the Schneier report?
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`MR. KUSHAN: Sure. If you could go to -- let's take a look at Slide
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`4. For example, we have discussed this in Paragraph 470 of Mr. Schneier's
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`report. This is where he is using the contents of the reply envelope after
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`they have been decrypted to do the installation.
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`

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`Case IPR2013-00080 (Patent 6,173,403)
`Case IPR2013-00081 (Patent 5,982,889)
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`And, also, we did go through the sequence of Pettitt with Dr. Wang.
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`If you can go to the next slide. So this is a passage from Dr. Wang's
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`deposition where we are working through kind of what the Pettitt scheme is.
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`And he is confirming here that there are six items of information inside the
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`encrypted reply envelope. This is a passage at Exhibit 2034, Page 235, 6
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`through 19. And then subsequent to the step is the decryption step. I am not
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`sure I have that as a demonstrative. But I would be happy to perhaps take
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`that up on our rebuttal if you want to follow up.
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`MR. MICALLEF: Good afternoon, Your Honors. My name is
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`Joe Micallef for the Petitioner. I am going to be dealing with the grounds
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`that are