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`Hearing before the PTAB
`
`August 16, 2016
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` __________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________________
`
` INTERNATIONAL BUSINESS MACHINES CORP.,
`
` Petitioner,
`
` v.
`
` INTELLECTUAL VENTURES I LLC,
`
` Patent Owner.
`
` ___________
`
` IPR2015-01481
`
` Patent 6,510,434 B1
`
` ____________
`
`Before MEREDITH C. PETRAVICK and SEILA F. MCSHANE,
`
`Administrative Patent Judges.
`
`August 16, 2016
`
`2:00 p.m.
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 2
`
`O n b e h a l f o f P E T I T I O N E R :
`
` B R E N T P . R A Y , E S Q U I R E
`
` E U G E N E G O R Y U N O V , E S Q U I R E
`
` K i r k l a n d & E l l i s , L L P
`
` 3 0 0 N o r t h L a S a l l e S t r e e t
`
` C h i c a g o , I l l i n o i s 6 0 6 5 4
`
` ( 3 1 2 ) 8 6 2 - 2 0 0 0
`
`O n b e h a l f o f P A T E N T O W N E R :
`
` J A M E S P . M U R P H Y , E S Q U I R E
`
` H E N R Y A . P E T R I , J R . , E S Q U I R E
`
` P o l s i n e l l i , L L P
`
` 1 4 0 1 E y e S t r e e t
`
` S u i t e 8 0 0
`
` W a s h i n g t o n , D C 2 0 0 0 5
`
` ( 2 0 2 ) 7 8 3 - 3 3 0 0
`
`VERITEXT LEGAL SOLUTIONS
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`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
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` P R O C E E D I N G S
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` THE COURT: We have received the email
`
`with the listings of the portions and have
`
`reviewed those portions. So could you tell us why
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`you think a motion to -- we should authorize you
`
`to file a motion to strike?
`
` MR. MURPHY: Yes, Your Honor. So the
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`issue we have with those portions is that the
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`Petitioner has changed their theory of Wical
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`regarding what the directed graph is.
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` And this really came to light through
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`the deposition of Dr. Jagadish. He had filed a
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`declaration with Petitioner's reply, so we deposed
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`him a second time. And during that deposition
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`what came out was that in Dr. Jagadish's opinion,
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`the directed graph does not include hierarchical
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`relationships.
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` And this is important because in the
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`petition and all the way through the proceeding,
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`the Petitioner had argued that the directed graph
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`includes the relationships between the categories.
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`It never specified which of those relationships,
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 4
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`and the only reading of the petition is that it
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`would have been any or all the relationships
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`between categories.
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` And I think that's the understanding the
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`Board had when it reviewed the Institution
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`Decision, the understanding Patent Owner had in
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`filing its response, and sort of the first
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`indication that Petitioner had changed position on
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`Wical, that the directed graph is only the
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`specific relationships, cross references, and
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`links.
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` The first time we became aware of that
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`was through the deposition of Dr. Jagadish. And
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`since we've never had a chance to respond to that
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`theory and present expert testimony. With that,
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`we think the appropriate action to take would be
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`to strike the arguments that they are trying to
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`make that are different and new from what was in
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`this petition.
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` THE COURT: All right. Petitioner,
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`would you like to respond?
`
` MR. RAY: Yes, Your Honor.
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
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`Page 5
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` The first thing I'll note is from a
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`procedural standpoint Petitioner does not believe
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`that a motion to strike is a proper mechanism here
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`to raise these points. The Board can determine
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`and does determine if a portion of the reply or
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`any evidence or arguments should be considered or
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`not at the time of its final decision.
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` And as just a matter of substance,
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`Petitioner believes that all the arguments that
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`are cited at the patent owner listing of portions
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`that they wish to strike are in fact disclosed in
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`the petition and the original declaration. We
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`don't believe there's any new arguments or
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`evidence here.
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` But I think, besides that point, this is
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`what the panel is entrusted to do at the time of
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`its final decision. So as the Patent Owner has
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`been permitted to do, it has submitted a list of
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`the proposed portions of the responsive
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`declaration and the reply that it believes are
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`new. To the extent that you wish to have put the
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`Board on notice of these portions, that's already
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
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`Page 6
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`been done.
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` But the Petitioner's position is that
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`the board can now act, as it always does in these
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`proceedings, as the gatekeeper to decide what it
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`relies upon and what it does not in the final
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`decision.
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` So the first point is that the motion to
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`strike should not be authorized because it's not a
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`proper mechanism to deal with this type of
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`argument.
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` The second point I would make from a
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`substantive standpoint is that the identification
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`of what is the metafile in Wical is clearly
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`disclosed in the petition and the supporting
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`declaration as the directed graph or a category
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`and a knowledge base. And how that directed graph
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`is created, for example, that's discussed in
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`paragraph 117 of Dr. Jagadish's declaration, that
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`has been known throughout this entire process.
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` So we're not understanding the --
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`whatever is alleged to be new here. The
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`identification of the directed graph as the
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 7
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`metafile has been known.
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` THE COURT: Can you tell me what pages
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`of the Patent Owner's response your argument
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`responds to in the Petitioner's reply?
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` MR. RAY: Sure. Bear with me for just a
`
`moment.
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` THE COURT: Okay.
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` MR. RAY: So, for example, the portions
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`of the reply address Patent Owner's response at
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`page 12.
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` THE COURT: Okay. And what page of the
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`petition is the argument about the directed graph
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`and the knowledge base of Wical.
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` MR. RAY: That occurs first at pages 9
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`and 10 of the petition when the directed graph is
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`discussed for a particular category and
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`identification of a metafile. It is discussed in
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`more detail at page 16 and 17. And the directed
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`graph is discussed in further detail, including
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`referring to exemplary pictures found in Wical.
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` And that is an argument that is repeated
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`throughout various portions of the petition as
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`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
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`that term metafile is used in different claims.
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` THE COURT: Okay. So if I'm
`
`understanding you correctly -- Mr. Ray?
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` MR. RAY: Yes.
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` THE COURT: You're saying that it's not
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`a new argument, and the reply is not outside the
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`scope of the opposition.
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` MR. RAY: That's correct, your Honor.
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` THE COURT: And Mr. Murphy, you are
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`saying that it is a new argument, and it's outside
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`the scope of the opposition.
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` MR. MURPHY: Yes, Your Honor, and if I
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`could get a minute just to respond to a point
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`Mr. Ray made.
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` First off, the motion to strike, I
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`think, would be appropriate here if there is
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`indeed the argument, as we contend, we never had a
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`chance to respond or reply to that. And while we
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`did file observations on Dr. Jagadish's testimony,
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`as you are well aware, those observations do not
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`permit a party to submit and brief any argument.
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` And regarding whether it's a new
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`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 9
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`argument or not, the issue, I don't think, is --
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`that we're raising is that they didn't suggest
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`that the directed graph is the metafile. They do
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`argue that the problem is that in the petition,
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`what the directed graph is, if you looked at page
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`10, which they cite to -- moving to page 10 -- it
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`talks about the knowledge base stores information
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`about relationships among categories using a
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`directed graph structure. And that's a quote.
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` So they don't specify what types of
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`relationships among categories. And I think, if
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`you go to page 29, you can see it again, where
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`they say the directed graph for a particular
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`category was related to categories and
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`relationship information about the categories.
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`For example, the lines and arrows in Figure 4
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`below, show how the categories are related.
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` And if we look at Figure 4, which is on
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`page 30, the only thing they have that's
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`highlighted at the very top is Leisure and
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`Recreation. They don't identify any of these
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`other relationships on there.
`
`VERITEXT LEGAL SOLUTIONS
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`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 10
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` And so the petition, the only reading of
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`this is that the directed graph includes all these
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`relationships indicated by the arrows in Figure 4
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`here. But what their expert has said during his
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`deposition is that actually the arrows you see in
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`Figure 4 that go down are not part of the directed
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`graph.
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` So that is -- the issue we have is where
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`they, you know, raise a new argument that was not
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`in the petition. Essentially, they went from the
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`directed graph is all these relationships to now
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`the directed graph is only specific relationships.
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`And -- which in Figure 4 they would say it's just
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`the curved arrows between France and Art Galleries
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`and Museums or the curved line between Places of
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`Interest and Art Galleries and Museums, but not
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`any of these vertical lines.
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` MR. RAY: Your Honor, may I briefly
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`respond? This is Mr. Ray.
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` THE COURT: Just one or two minutes, and
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`then I'm going to consult -- take a moment to
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`review the cited portions and consult with Judge
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`VERITEXT LEGAL SOLUTIONS
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`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 11
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`McShane, and then we're going to come back on the
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`line and give a ruling.
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` MR. RAY: Your Honor, very briefly. I
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`think that what Patent Owner has done in referring
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`to the issue that has just been raised is not a
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`whole description of what was presented in the
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`petition in terms of the directed graph.
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` Referring you back to page 16 and 17 of
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`the petition, the directed graph is talked about
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`in terms of maybe a variety of arrowed lines
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`between the graph. And what is also disclosed in
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`the petition and the supporting declaration is the
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`notion that Wical references -- discloses to one
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`skilled in the art that you take categories in a
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`knowledge base and you augment them using what's
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`called cross references and links to create a
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`directed graph based on how you would like
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`particular categories to be related.
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` The whole point of the reference is that
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`you enable somebody who is skilled in the art to
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`create their own graph by how they choose to
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`relate various categories.
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`VERITEXT LEGAL SOLUTIONS
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`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 12
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` That's what the example not only on
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`pages 16 and 17 shows, but also what's called out
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`in the declaration as the opinion of Dr. Jagadish
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`in terms of what the directed graph is in Wical.
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` I don't think it's accurate to refer to
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`a particular single example called out in the
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`petition because, very clearly from the petition
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`and the declaration, the notion of what a directed
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`graph is is broader than that in Wical, and the
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`language of our submission supports that. I don't
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`think it's new at all.
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` THE COURT: Okay. Thank you. I'm going
`
`to pause for a minute and consult with Judge
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`McShane. Please hold the line.
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` (Whereupon, a brief recess was taken.)
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` THE COURT: All right. This is Judge
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`Petravick. Judge McShane and I are both back on
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`the line. Is counsel for Patent Owner still
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`there?
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` MR. MURPHY: Yes, Your Honor.
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` THE COURT: Is counsel for Petitioner
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`still there?
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
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`IV I LLC
`Exhibit 2005
`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 13
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` MR. RAY: Yes, Your Honor.
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` THE COURT: Having now just reviewed the
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`cited portions and the portions in the associated
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`email, we are going to deny authorization to file
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`a motion to strike. We find that the arguments in
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`the Petitioner's reply to be consistent with the
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`petition and is within the scope of the Patent
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`Owner's response. We do not feel that a motion to
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`strike is warranted at this time. And so we deny
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`authorization.
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` We will enter a -- please file the
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`transcript into the record, and once we get that
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`we will send out an order summarizing our ruling
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`here today.
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` Are there any other questions?
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` MR. MURPHY: Just one point, Your
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`Honor --
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` THE COURT: We've already heard what you
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`had to say on the decision. We've considered it
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`and made our decision. Do you have any other
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`questions about procedures?
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` MR. MURPHY: No, Your Honor.
`
`VERITEXT LEGAL SOLUTIONS
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`
`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 14
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` THE COURT: From the Petitioner?
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` MR. RAY: No, Your Honor.
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` THE COURT: Are there any other issues?
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` Hearing none, we will be adjourned.
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`Thank you.
`
` (Whereupon, at 2:19 p.m., the
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` proceedings were adjourned.)
`
` * * * * *
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`VERITEXT LEGAL SOLUTIONS
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`IV I LLC
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`

`
`Hearing before the PTAB
`
`August 16, 2016
`
`Page 15
`
` CERTIFICATE OF NOTARY PUBLIC
`
` I, CONSTANCE HUNT RHODES, the officer
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`before whom the foregoing deposition was taken, do
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`hereby certify that the witness whose testimony
`
`appears in the foregoing deposition was duly sworn
`
`by me; that the testimony of said witness was
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`taken by me in stenotypy and thereafter reduced to
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`typewriting under my direction; that said
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`deposition is a true record of the testimony given
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`by said witness; that I am neither counsel for,
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`related to, nor employed by any of the parties to
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`the action in which this deposition was taken; and
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`further, that I am not a relative or employee of
`
`any attorney or counsel employed by the parties
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`thereto, nor financially or otherwise interested
`
`in the outcome of the action.
`
` <%Signature%>
`
` CONSTANCE HUNT RHODES
`
` Notary Public in and for the
`
` State of Maryland
`
`My commission expires:
`
`September 21, 2019
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`VERITEXT LEGAL SOLUTIONS
`202-803-8830
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`IV I LLC
`Exhibit 2005
`
`

`
`[& - eye]
`
`&
`
`& 2:3
`
`1
`10 7:15 9:6,6
`117 6:18
`12 7:10
`1401 2:8
`16 1:15 7:18 11:8
`12:2
`17 7:18 11:8 12:2
`2
`20005 2:9
`2016 1:15
`2019 15:21
`202 2:10
`21 15:21
`29 9:12
`2:00 1:16
`2:19 14:6
`3
`
`30 9:19
`300 2:3
`312 2:4
`
`4
`4 9:16,18 10:3,6,13
`6
`6,510,434 1:9
`60654 2:4
`7
`783-3300 2:10
`8
`
`800 2:9
`862-2000 2:4
`9
`
`9 7:14
`
`a
`accurate 12:5
`act 6:3
`action 4:16 15:12,16
`address 7:9
`adjourned 14:4,7
`administrative 1:13
`
`Hearing before the PTAB
`
`alleged 6:21
`appeal 1:3
`appears 15:5
`appropriate 4:16
`8:16
`argue 9:4
`argued 3:20
`argument 6:10 7:3
`7:12,21 8:6,10,17
`8:21 9:1 10:9
`arguments 4:17 5:6
`5:9,13 13:5
`arrowed 11:10
`arrows 9:16 10:3,5
`10:14
`art 10:14,16 11:14
`11:20
`associated 13:3
`attorney 15:14
`augment 11:15
`august 1:15
`authorization 13:4
`13:10
`authorize 3:5
`authorized 6:8
`aware 4:12 8:20
`b
`
`b1 1:9
`back 11:1,8 12:17
`base 6:16 7:13 9:7
`11:15
`based 11:17
`bear 7:5
`behalf 2:1,6
`believe 5:2,13
`believes 5:9,20
`board 1:3 4:5 5:4,22
`6:3
`brent 2:2
`brief 8:21 12:15
`briefly 10:18 11:3
`broader 12:9
`business 1:5
`c
`c 1:12 3:1
`called 11:16 12:2,6
`
`categories 3:21 4:3
`9:8,11,14,15,17
`11:14,18,22
`category 6:15 7:16
`9:14
`certificate 15:1
`certify 15:4
`chance 4:14 8:18
`changed 3:9 4:8
`chicago 2:4
`choose 11:21
`cite 9:6
`cited 5:10 10:22
`13:3
`claims 8:1
`clearly 6:13 12:7
`come 11:1
`commission 15:21
`considered 5:6
`13:19
`consistent 13:6
`constance 15:2,19
`consult 10:21,22
`12:13
`contend 8:17
`corp 1:5
`correct 8:8
`correctly 8:3
`counsel 12:18,21
`15:10,14
`court 3:2 4:20 7:2,7
`7:11 8:2,5,9 10:20
`12:12,16,21 13:2,18
`14:1,3
`create 11:16,21
`created 6:17
`cross 4:10 11:16
`curved 10:14,15
`d
`
`d 3:1
`dc 2:9
`deal 6:9
`decide 6:4
`decision 4:6 5:7,17
`6:6 13:19,20
`declaration 3:13
`5:12,20 6:15,18
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`VERITEXT LEGAL SOLUTIONS
`202-803-8830
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`August 16, 2016
`Page 1
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`11:12 12:3,8
`deny 13:4,9
`deposed 3:13
`deposition 3:12,14
`4:13 10:5 15:3,5,9
`15:12
`description 11:6
`detail 7:18,19
`determine 5:4,5
`different 4:18 8:1
`directed 3:10,16,20
`4:9 6:15,16,22 7:12
`7:15,18 9:3,5,9,13
`10:2,6,11,12 11:7,9
`11:17 12:4,8
`direction 15:8
`disclosed 5:11 6:14
`11:11
`discloses 11:13
`discussed 6:17 7:16
`7:17,19
`dr 3:12,15 4:13 6:18
`8:19 12:3
`duly 15:5
`e
`
`e 3:1,1
`ellis 2:3
`email 3:2 13:4
`employed 15:11,14
`employee 15:13
`enable 11:20
`enter 13:11
`entire 6:19
`entrusted 5:16
`esquire 2:2,2,7,7
`essentially 10:10
`eugene 2:2
`evidence 5:6,14
`example 6:17 7:8
`9:16 12:1,6
`exemplary 7:20
`expert 4:15 10:4
`expires 15:21
`extent 5:21
`eye 2:8
`
`IV I LLC
`Exhibit 2005
`
`

`
`[f - petri]
`
`f
`
`f 1:12
`fact 5:11
`feel 13:8
`figure 9:16,18 10:3
`10:6,13
`file 3:6 8:19 13:4,11
`filed 3:12
`filing 4:7
`final 5:7,17 6:5
`financially 15:15
`find 13:5
`first 4:7,12 5:1 6:7
`7:14 8:15
`foregoing 15:3,5
`found 7:20
`france 10:14
`further 7:19 15:13
`g
`
`g 3:1
`galleries 10:14,16
`gatekeeper 6:4
`give 11:2
`given 15:9
`go 9:12 10:6
`going 10:21 11:1
`12:12 13:4
`goryunov 2:2
`graph 3:10,16,20
`4:9 6:15,16,22 7:12
`7:15,19 9:3,5,9,13
`10:2,7,11,12 11:7,9
`11:11,17,21 12:4,9
`h
`heard 13:18
`hearing 14:4
`henry 2:7
`hierarchical 3:16
`highlighted 9:20
`hold 12:14
`honor 3:7 4:22 8:8
`8:12 10:18 11:3
`12:20 13:1,17,22
`14:2
`hunt 15:2,19
`
`Hearing before the PTAB
`
`i
`identification 6:12
`6:22 7:17
`identify 9:21
`illinois 2:4
`important 3:18
`include 3:16
`includes 3:21 10:2
`including 7:19
`indicated 10:3
`indication 4:8
`information 9:7,15
`institution 4:5
`intellectual 1:7
`interest 10:16
`interested 15:15
`international 1:5
`ipr2015-01481 1:9
`issue 3:8 9:1 10:8
`11:5
`issues 14:3
`j
`jagadish 3:12 4:13
`12:3
`jagadish's 3:15 6:18
`8:19
`james 2:7
`jr 2:7
`judge 10:22 12:13
`12:16,17
`judges 1:13
`k
`kirkland 2:3
`know 10:9
`knowledge 6:16
`7:13 9:7 11:15
`known 6:19 7:1
`l
`language 12:10
`lasalle 2:3
`leisure 9:20
`light 3:11
`line 10:15 11:2
`12:14,18
`lines 9:16 10:17
`11:10
`
`links 4:11 11:16
`list 5:18
`listing 5:10
`listings 3:3
`llc 1:7
`llp 2:3,8
`look 9:18
`looked 9:5
`m
`machines 1:5
`maryland 15:20
`matter 5:8
`mcshane 1:12 11:1
`12:14,17
`mechanism 5:3 6:9
`meredith 1:12
`metafile 6:13 7:1,17
`8:1 9:3
`minute 8:13 12:13
`minutes 10:20
`moment 7:6 10:21
`motion 3:5,6 5:3 6:7
`8:15 13:5,8
`moving 9:6
`murphy 2:7 3:7 8:9
`8:12 12:20 13:16,22
`museums 10:15,16
`n
`
`n 3:1
`neither 15:10
`never 3:22 4:14
`8:17
`new 4:18 5:13,21
`6:21 8:6,10,22 10:9
`12:11
`north 2:3
`notary 15:1,19
`note 5:1
`notice 5:22
`notion 11:13 12:8
`o
`
`o 3:1
`observations 8:19
`8:20
`occurs 7:14
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`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`August 16, 2016
`Page 2
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`office 1:1
`officer 15:2
`okay 7:7,11 8:2
`12:12
`once 13:12
`opinion 3:15 12:3
`opposition 8:7,11
`order 13:13
`original 5:12
`outcome 15:16
`outside 8:6,10
`owner 1:7 2:6 4:6
`5:10,17 11:4 12:18
`owner's 7:3,9 13:8
`p
`p 2:2,7 3:1
`p.m. 1:16 14:6
`page 7:10,11,18 9:5
`9:6,12,19 11:8
`pages 7:2,14 12:2
`panel 5:16
`paragraph 6:18
`part 10:6
`particular 7:16 9:13
`11:18 12:6
`parties 15:11,14
`party 8:21
`patent 1:1,3,7,9,13
`2:6 4:6 5:10,17 7:3
`7:9 11:4 12:18 13:7
`pause 12:13
`permit 8:21
`permitted 5:18
`petition 3:19 4:1,19
`5:12 6:14 7:12,15
`7:22 9:4 10:1,10
`11:7,9,12 12:7,7
`13:7
`petitioner 1:5 2:1
`3:9,20 4:8,20 5:2,9
`12:21 14:1
`petitioner's 3:13 6:2
`7:4 13:6
`petravick 1:12
`12:17
`petri 2:7
`
`IV I LLC
`Exhibit 2005
`
`

`
`August 16, 2016
`Page 3
`
`top 9:20
`trademark 1:1
`transcript 13:12
`trial 1:3
`true 15:9
`trying 4:17
`two 10:20
`type 6:9
`types 9:10
`typewriting 15:8
`u
`understanding 4:4
`4:6 6:20 8:3
`united 1:1
`v
`
`v 1:6
`variety 11:10
`various 7:22 11:22
`ventures 1:7
`vertical 10:17
`w
`warranted 13:9
`washington 2:9
`way 3:19
`we've 4:14 13:18,19
`went 10:10
`wical 3:9 4:9 6:13
`7:13,20 11:13 12:4
`12:9
`wish 5:11,21
`witness 15:4,6,10
`
`[pictures - witness]
`
`pictures 7:20
`places 10:15
`please 12:14 13:11
`point 5:15 6:7,11
`8:13 11:19 13:16
`points 5:4
`polsinelli 2:8
`portion 5:5
`portions 3:3,4,8
`5:10,19,22 7:8,22
`10:22 13:3,3
`position 4:8 6:2
`present 4:15
`presented 11:6
`problem 9:4
`procedural 5:2
`procedures 13:21
`proceeding 3:19
`proceedings 6:4
`14:7
`process 6:19
`proper 5:3 6:9
`proposed 5:19
`public 15:1,19
`put 5:21
`
`q
`questions 13:15,21
`quote 9:9
`r
`
`r 3:1
`raise 5:4 10:9
`raised 11:5
`raising 9:2
`ray 2:2 4:22 7:5,8
`7:14 8:3,4,8,14
`10:18,19 11:3 13:1
`14:2
`reading 4:1 10:1
`really 3:11
`received 3:2
`recess 12:15
`record 13:12 15:9
`recreation 9:21
`reduced 15:7
`refer 12:5
`reference 11:19
`
`Hearing before the PTAB
`
`references 4:10
`11:13,16
`referring 7:20 11:4
`11:8
`regarding 3:10 8:22
`relate 11:22
`related 9:14,17
`11:18 15:11
`relationship 9:15
`relationships 3:17
`3:21,22 4:2,10 9:8
`9:11,22 10:3,11,12
`relative 15:13
`relies 6:5
`repeated 7:21
`reply 3:13 5:5,20
`7:4,9 8:6,18 13:6
`respond 4:14,21
`8:13,18 10:19
`responds 7:4
`response 4:7 7:3,9
`13:8
`responsive 5:19
`review 10:22
`reviewed 3:4 4:5
`13:2
`rhodes 15:2,19
`right 4:20 12:16
`ruling 11:2 13:13
`s
`
`s 3:1
`saying 8:5,10
`scope 8:7,11 13:7
`second 3:14 6:11
`see 9:12 10:5
`seila 1:12
`send 13:13
`september 15:21
`show 9:17
`shows 12:2
`signature 15:18
`single 12:6
`skilled 11:14,20
`somebody 11:20
`sort 4:7
`specific 4:10 10:12
`
`specified 3:22
`specify 9:10
`standpoint 5:2 6:12
`state 15:20
`states 1:1
`stenotypy 15:7
`stores 9:7
`street 2:3,8
`strike 3:6 4:17 5:3
`5:11 6:8 8:15 13:5,9
`structure 9:9
`submission 12:10
`submit 8:21
`submitted 5:18
`substance 5:8
`substantive 6:12
`suggest 9:2
`suite 2:9
`summarizing 13:13
`supporting 6:14
`11:12
`supports 12:10
`sure 7:5
`sworn 15:5
`t
`take 4:16 10:21
`11:14
`taken 12:15 15:3,7
`15:12
`talked 11:9
`talks 9:7
`tell 3:4 7:2
`term 8:1
`terms 11:7,10 12:4
`testimony 4:15 8:19
`15:4,6,9
`thank 12:12 14:5
`theory 3:9 4:15
`thereto 15:15
`thing 5:1 9:19
`think 3:5 4:4,16
`5:15 8:16 9:1,11
`11:4 12:5,11
`time 3:14 4:12 5:7
`5:16 13:9
`today 13:14
`
`VERITEXT LEGAL SOLUTIONS
`202-803-8830
`
`IV I LLC
`Exhibit 2005