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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________________
` OLD REPUBLIC GENERAL INSURANCE GROUP, INC., OLD
` REPUBLIC INSURANCE COMPANY; OLD REPUBLIC TITLE
` INSURANCE GROUP, INC.; AND OLD REPUBLIC NATIONAL
` TITLE INSURANCE COMPANY,
` Petitioners,
` vs.
` INTELLECTUAL VENTURES I, LLC
` Patent Owner.
` ----------------------------
` Case IPR2016-00020
` Case IPR2016-00019
` ----------------------------
` VIDEO DEPOSITION OF JEFFREY F. NAUGHTON, Ph.D.
` Washington, D.C.
` Thursday, June 23, 2016, 9:12 a.m.
`
`Job no. 108849
`Reported by: Laurie Donovan, RPR, CRR
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________________
` OLD REPUBLIC GENERAL INSURANCE GROUP, INC., OLD
` REPUBLIC INSURANCE COMPANY; OLD REPUBLIC TITLE
` INSURANCE GROUP, INC.; AND OLD REPUBLIC NATIONAL
` TITLE INSURANCE COMPANY,
` Petitioners,
` vs.
` INTELLECTUAL VENTURES I, LLC
` Patent Owner.
` ----------------------------
` Case IPR2016-00020
` Case IPR2016-00019
` ----------------------------
` VIDEO DEPOSITION OF JEFFREY F. NAUGHTON, Ph.D.
` Washington, D.C.
` Thursday, June 23, 2016, 9:12 a.m.
`
`Job no. 108849
`Reported by: Laurie Donovan, RPR, CRR
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` Video Deposition of
` Jeffrey F. Naughton, Ph.D.
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`Held at the offices of:
` Sidley Austin
` 1501 K Street, NW
` Washington, D.C. 20005
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` Taken pursuant to notice, before
` Laurie Donovan, Registered Professional
` Reporter, Certified Realtime Reporter and
` Notary public in and for the District of
` Columbia.
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` A P P E A R A N C E S
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`ON BEHALF OF PEITIONERS:
` Sidley Austin
` 1501 K Street, NW
` Washington, D.C. 20005
` By: Samuel Dillon, Esq.
` Joseph Micallef, Esq.
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`ON BEHALF OF PATENT OWNER:
` Polsinelli
` 1000 Louisiana Street
` Houston, Texas 77002
` By: James Murphy, Esq.
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`ALSO PRESENT:
` Jordan Mummert, videographer
` James Hietala (via phone)
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` EXAMINATION INDEX
` PAGE
`EXAMINATION BY MR. MURPHY . . . . . . . . . 6, 178
`EXAMINATION BY MR. DILLON . . . . . . . . . . 172
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` E X H I B I T S
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` Jeffrey F. Naughton, Ph.D.
` P R O C E E D I N G S
` THE VIDEOGRAPHER: This is the
`start of the video deposition of Dr. Jeffrey
`Naughton in the matter of Old Republic
`General Insurance Group, Inc., et al, versus
`Intellectual Ventures, I, LLC, in the United
`State Patent & Trademark Office before the
`Patent Trial & Appeal Board, case number
`IPR2016-00019 and IPR2016-00020.
` This deposition is taking place at
`1501 K Street, Northwest, Washington, D.C.,
`on June 23, 2016, at approximately 9:12 a.m.
`My name is Jordan Mummert from TSG Reporting,
`Inc., and I'm the legal video specialist.
`The court reporter is Laurie Donovan in
`association with TSG Reporting.
` Would counsel please introduce
`yourselves.
` MR. MURPHY: This is James Murphy
`at Polsinelli, P.C. I'm here representing
`Intellectual Ventures I, LLC, and on the
`phone with me is James Hietala, who is
`in-house counsel at Intellectual Ventures.
` MR. DILLON: And I'm Sam Dillon
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` Jeffrey F. Naughton, Ph.D.
` here for petitioners, the Old Republic
` companies. I'm with Sidley Austin, LLP.
` With me is Joseph Micallef, also of Sidley
` Austin, LLP.
` THE VIDEOGRAPHER: The court
` reporter may swear in the witness.
` JEFFREY F. NAUGHTON, Ph.D.,
` having been first duly sworn, testified
` upon his oath as follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. MURPHY:
` Q Thank you for coming here today,
`Dr. Naughton, and before we begin, have you had
`your deposition taken before?
` A Yes.
` Q Okay. Let me just go over some of the
`basics of the deposition just to remind you then.
` I'm going to be asking you questions and
`you'll be providing the answers. Your counsel
`will object from time to time, but please answer
`the question unless you're instructed by your
`counsel not to.
` And if you don't understand any of my
`questions, let me know, and I'll try to rephrase
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` Jeffrey F. Naughton, Ph.D.
`it if I can.
` If you need a break, also let me know.
`I will accommodate you as soon as I can. I want
`to finish whatever line of questioning I was
`working on, but I will certainly take a break when
`I can.
` Now, is there anything today that would
`prevent you from providing full, complete, and
`true answers to my questions?
` A No.
` Q So no medications or health conditions
`that might interfere with your testimony today?
` A Not that I'm aware of.
` Q And do you understand that you're here
`today to testify in connection with the
`declaration you've submitted in connection with
`some IPR proceedings?
` A Yes.
` Q And those IPR proceedings are identified
`as 2016-00019 and 2016-0020. Does that sound
`right?
` A That sounds right.
` Q And they relate to US patent 6,510,434?
` A That sounds right. I remember the '434.
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` Jeffrey F. Naughton, Ph.D.
` Q And if I refer to that patent as the
`"'434 patent," you'll know what I'm referring to?
` A Yes.
` Q Okay. When were you approached to be
`retained in this matter?
` A Boy, I don't -- honestly, I don't recall
`exactly when.
` Q Was it about a year ago, two years ago?
` A I would, I would honestly have to
`speculate. I could check, check my emails if you
`wanted me to.
` Q Okay. So you don't have a rough idea?
` A It would just be a guess.
` Q And who retained you to work on this
`matter?
` A What do you mean "who retained"?
` Q Was it counsel from Sidley Austin who
`engaged you in this?
` A Yes.
` Q And have you communicated with anyone
`other than counsel at Sidley Austin on this
`matter?
` A No.
` Q Did you have any communication with
`
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` Jeffrey F. Naughton, Ph.D.
`anyone at Old Republic?
` A No, I didn't.
` Q And did you prepare for today's
`deposition?
` A Yes.
` Q And what did you do to prepare for
`today's deposition?
` A I reread my declaration, yeah.
` Q Did you read any of the prior art that's
`involved in the proceeding?
` A Yes.
` Q Okay. So you reviewed that to prepare
`for today?
` A Yes.
` Q And what about the '434 patent; did you
`review that to prepare for today?
` A Yes.
` Q Did you review the Patent Trial & Appeal
`Board's institution decision?
` MR. DILLON: Object to the form.
` THE WITNESS: I read them.
`BY MR. MURPHY:
` Q Okay, and when I refer to the Patent
`Trial & Appeal Board's institution decision, do
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` Jeffrey F. Naughton, Ph.D.
`you know what I'm referring to?
` A I think so.
` Q It's a decision by the board that
`instituted the IPR proceedings. Does that sound
`familiar?
` A It does sound familiar.
` Q Do you recall reviewing a document
`entitled "Intellectual Ventures' Preliminary
`Response"?
` A I'm trying to recall if that was the
`title. I remember a response from Intellectual
`Ventures.
` Q Okay. You reviewed Intellectual
`Ventures' response prior to this deposition?
` A I read it prior to the deposition, yes.
` Q Did you read it to prepare for today's
`deposition?
` A I mean I'm -- yes, I guess, because I, I
`would not have read it if I wasn't going to be
`deposed. In that sense, yes.
` Q When did you read it? Did you read it
`in the last couple of days, or are you talking
`about you read it a couple months ago?
` A I would say weeks.
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` Jeffrey F. Naughton, Ph.D.
` Q Weeks.
` Did you review any documents from any
`other IPR proceedings to prepare for today's
`deposition?
` A No.
` Q Are you aware that IBM filed some IPR
`petitions against the '434 patent?
` A I believe I saw that in one of the
`documents.
` Q But to the best of your knowledge,
`you've never read a document from the IBM IPR
`proceedings?
` A I have not.
` Q And are you aware that the expert
`witnesses in that proceeding had been deposed?
` A I'm not sure about that.
` Q But you never read a deposition
`transcript from the IBM IPR proceedings?
` A No.
` Q And you never read any expert
`declarations from the IBM IPR proceedings?
` A No.
` Q And who did you meet with to prepare for
`today's deposition?
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` A I met with the Sidley attorneys.
` Q Is it the two attorneys that are present
`in the room?
` A Yes.
` Q And how long did you guys meet for?
` A Roughly an afternoon.
` Q Now I'm handing the witness what's been
`marked as Exhibit 1003 in both IPR proceedings,
`and do these documents look familiar to you,
`Dr. Naughton?
` A Let me take a moment to look.
` (Witness peruses document.)
` THE WITNESS: Yes.
`BY MR. MURPHY:
` Q And what are these documents?
` A These are my declaration.
` Q And you signed both of these
`declarations; is that right?
` A Yes. At least I believe I did. Yes,
`yes.
` Q And when you reviewed the declarations
`to prepare for today's deposition, did you notice
`any errors or mistakes that you would like to
`correct?
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` Jeffrey F. Naughton, Ph.D.
` A I've changed my job since I wrote the
`declaration.
` Q What's your current job?
` A I work for Google now.
` Q So you still agree with all the
`statements you make in your declaration?
` A Yes.
` Q If you'd turn to paragraph 7 of your
`declaration, and just for clarity, let's use the
`declaration in the -00019 proceeding. Let me know
`when you're there.
` A I'm there.
` Q In this paragraph you talk about some of
`the research you performed; is that right?
` A Yes.
` Q Did any of that research involve XML
`databases?
` A In the mid '90s, no.
` Q In paragraph 8 you refer to the late
`'90s, and there did your research entail XML
`databases?
` A Yes.
` Q Do you recall when you first started
`working on or researching XML databases?
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` Jeffrey F. Naughton, Ph.D.
` A I don't recall an exact date.
` Q Is the paper you list here, "Relational
`Databases for XML Queries: Opportunities and
`Limitations," is that the first paper you
`published relating to XML?
` A I would have to check my CV to be sure,
`but it's, it's close to it, if it's not closer,
`the first.
` Q And why did you start researching XML?
` A Well, I can give a general reason. It
`was becoming an interesting technology for storing
`and exchanging data, and as a professor, we are
`always looking for things like that.
` Q And you say it was an interesting
`technology. What made it interesting to you?
` A One of the things that made it
`interesting was making, making documents available
`for a different kind of querying. It was
`different from the relational database systems we
`worked on mostly, so it was new. That made it
`interesting.
` Q Sorry. I missed the first part of your
`answer. Documents different from what?
` A Relational database management systems.
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` Jeffrey F. Naughton, Ph.D.
` Q Okay. Did your paper in 1999, the
`relational databases one, involve indexes?
` A Boy, that's -- that work was done prior
`to '99, so it's at least 15 years ago. I'm not
`sure exactly what was in the paper. I honestly
`don't know if it used indexes or not.
` Q Would it have involved XML tags?
` A Yes, it would have involved XML tags.
` Q And why are you able to remember that
`more clearly than the indexes?
` A I'm not sure I can explain why I do
`remember it. This paper -- my recollection of it
`is that this paper was largely about how you take
`an XML document and store it in a relational
`database system.
` Q Does it also involve how to search for
`the documents in that database?
` A Again, I, I would have to read that
`paper to answer definitively, but I don't believe
`searching was the focus of it.
` Q We've been talking about XML, but could
`you give us a definition of what XML is, just for
`the record?
` A XML is a subset of SGML.
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` Q Is it an acronym for "extended markup
`language"?
` A Yes.
` Q And XML is a standard, correct?
` A Yes, there is an XML standard.
` Q And what organization sets that
`standard?
` A My recollection is it's the W3C, but I'm
`not positive.
` Q And do you recall when the XML standard
`was first released?
` A Not precisely I don't recall.
` Q You mentioned a relational database.
`Can you tell me what a relational database is?
` A It's -- a relational database, in the
`abstract, is a database for what you store are --
`mathematically it's called sets of tuples.
`Examples of relational databases you might have
`heard of, implementations of them are Microsoft
`SQL server, IBM DB2, Oracle.
` Q And what was the benefit of using XML
`queries with a relational database?
` A I believe the goal of doing that was
`there was already substantial effort invested in
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`query processors for relational systems, and the
`hope was that we could reuse that for XML queries.
` Q And so there was a large body of
`research already about relational databases; is
`that right?
` A That's correct. There was a large body
`of research about relational databases.
` Q So you were trying to apply this new XML
`standard to the existing research regarding
`relational databases?
` A Could you say, say that one more time?
` Q So you were trying to apply XML, which
`was new in the late 1990s, to the preexisting
`knowledge about relational databases?
` A I'm, I'm hesitating about the "apply."
`We were trying to use relational database
`technology to support XML queries.
` Q And were you the first group to do that?
` A I don't know that we were the very
`first. We were among the first.
` Q Were there other individuals or groups
`also trying to do similar research to yours at
`that time?
` A Yes, there were.
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` Jeffrey F. Naughton, Ph.D.
` Q You mentioned your paper had been cited
`over 1,500 times. Is that a large number of
`citations in this field?
` A Yes, that's a fairly good number of
`citations.
` Q And what was it about your paper that
`garnered so many citations?
` A I could speculate. You'd have to ask
`the people who cited it to be sure.
` Q And in the late 1990s when you wrote
`this paper, what was the meaning of "database" to
`those of skill in the art?
` A What was the meaning of "database"? I
`think it was an overloaded term. Sometimes it
`would refer to an organized collection of data in
`the sense that it's the data itself. Other times
`it referred to the systems that process that kind
`of data. So it would refer to the Oracle system
`as a database.
` Q So it could refer either to sort of the
`object storing the data or the software that is
`going to retrieve the data. Does that sound
`accurate?
` A Not quite.
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` Q The -- so the first example you
`mentioned was storing data, right?
` A What I meant to say, the data that is
`stored, so you could describe that mathematically
`without any system actually storing. You know,
`it's like this collection of tables.
` Q So in a very simple example, a table
`could be a database because it's storing data in
`the table; is that what you mean?
` A Let's see. I mean you could call a
`single table a database, and I would use that to
`refer to the contents of the table. What are the
`rows and the, you know, what are the values in the
`rows, all of that.
` Q So in that example, database would refer
`to the content inside the table rather than the
`structure of the table?
` A Fair point. It's both.
` Q Okay. So it's both the content and the
`structure of the table in that example?
` A Mm-hmm.
` Q And then in the second example you gave,
`you were talking about, I believe, the method of
`retrieving data. Can you describe what you meant
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` Jeffrey F. Naughton, Ph.D.
`by that?
` A Well, yes. It would be most proper to
`say a relational database management system is
`what I'm referring to in this, in this context,
`but as a shorthand, people often use the word, the
`term "database" to refer to that.
` Q Do you recall if there were any publicly
`available XML databases prior to 2000?
` MR. DILLON: Objection to
` foundation.
` THE WITNESS: I don't recall.
`BY MR. MURPHY:
` Q If you turn to paragraph 17 in the
`declaration.
` A Okay.
` Q In 17 and going onward through paragraph
`45, you discuss your understanding of the legal
`standards for patentability; is that right?
` A That is correct.
` Q Were these standards given to you by
`counsel for -- or counsel at Sidley Austin?
` A Yes, they were.
` Q And so in coming up with your opinions,
`you did your best to follow the standards that you
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` Jeffrey F. Naughton, Ph.D.
`list here in paragraphs 17 through 45?
` A Yes.
` Q But you're not testifying as an expert
`on any of the legal principles in these standards,
`are you?
` A No, I'm not.
` Q If you turn to paragraph 33, it says you
`applied these standards to evaluate whether the
`claims of the '434 patent would have been
`considered obvious in September 2001; is that
`right?
` A That is right.
` Q So in your analysis you use
`September 2001 as the date to evaluate the state
`of technology?
` A Yes. It's an approximate date, but yes.
` Q And did you ever consider if the claims
`would have been obvious under any earlier dates?
` A I'd have to say it was for that time
`frame, right around 2000/2001. That's what I
`would say.
` Q Okay, so the end of 1999, December of
`1999, you never used that date to determine if the
`claims were obvious?
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` Jeffrey F. Naughton, Ph.D.
` A I, I don't believe anything happened in
`there that would change my obvious consideration.
` Q But did you evaluate the claims with
`respect to December 1999?
` A I'm hesitating here, because, you know,
`this was 15 years ago, and for me the obviousness
`was from about that time, so I'm just -- I, I
`would not say that I explicitly thought of 1998,
`1999, 2000. I just, you know, this, this is the
`time frame I was thinking.
` Q And by "time frame," you're referring to
`1998 to 2001?
` A That's about right, yes.
` Q And so when you considered whether the
`claims would have been obvious, you did so in
`light of a time frame of 1998 to 2001?
` A I believe my obviousness arguments were
`valid for that time period.
` Q Okay, but just for clarity, when you
`evaluated the claims, you considered whether they
`would have been obvious at any time in the time
`period from 1998 to 2001?
` A I didn't have specific start and end
`dates in my mind when I did it.
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` Jeffrey F. Naughton, Ph.D.
` Q So you just evaluate the claims to sort
`of a general three-year time period; is that
`right?
` A I don't -- I wouldn't even say the
`three-year period. Approximately in that time
`frame. There were no sharp cutoffs.
` Q But in the time period from 1998 to
`2001, the technology regarding XML was changing,
`wasn't it?
` A Yes.
` Q So what may have been obvious in 2001
`may not have been obvious in 1998; don't you
`agree?
` A It is possible that something could be
`obvious in 2001 and not in '98.
` Q And it's possible something could have
`been obvious in September of 2001 but not obvious
`in December of 1999; is that right?
` A It is possible.
` Q And if you turn to paragraph 42 of your
`declaration.
` A Yes.
` Q And if you go to page 13 with the
`sentence starting "as such."
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` Jeffrey F. Naughton, Ph.D.
` A Mm-hmm.
` Q In that sentence you state, "As such,
`the prior art considered can be directed to any
`need or problem known in the field of endeavor in
`September 2001."
` So did you consider only problems known
`in the field in September of 2001?
` A I considered problems that were known in
`September 2001.
` Q And needs in the field that were known
`in September of 2001?
` A I'm sorry. I missed the first --
` Q Needs. Your statement mentions needs or
`problems.
` MR. DILLON: Object to the form.
` THE WITNESS: I did. I considered
` needs known in 2001.
`BY MR. MURPHY:
` Q Did you consider any needs or problems
`known in the field earlier than September 2001?
` A Yes, in the sense that many needs known
`in 2001 were known earlier also.
` Q By 2001, some of those earlier needs may
`have been solved; is that right?
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` Jeffrey F. Naughton, Ph.D.
` A It is possible that earlier needs could
`be solved.
` Q So the need or problem existing in
`December 1999 may no longer exist in September
`2001; is that right?
` MR. DILLON: Objection. Form.
` THE WITNESS: I think for me, if
` the need or problem, even if it's solved,
` it's known. So your question is was it not a
` need or problem later, right?
`BY MR. MURPHY:
` Q Right. So if there's a problem in,
`let's say, December of 1999, and someone comes up
`with a solution in January of 2000, would it still
`be a problem in September 2001?
` A Yes.
` Q Okay, and why would it be a problem even
`though there's a solution for it?
` A It's a problem because -- well, it could
`be a solved problem. It could be that there's a
`need for a better solution for the problem.
` Q And so in that sense, the problem is
`that the solution itself has issues, but you want
`to make an even better solution; is that right?
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` Jeffrey F. Naughton, Ph.D.
` MR. DILLON: Objection. Form.
` THE WITNESS: I, I think I said two
` things. One is that even if it's a solved
` problem, it's a problem, but the second part
` saying you may need a better solution, I did
` say that. That would rely on the solution, a
` defect in the solution.
`BY MR. MURPHY:
` Q If you turn to paragraph 46 of your
`declaration. You state that the -- you understand
`the effective filing date of the '434 patent is
`December 29, 1999; is that right?
` A That's right.
` Q Why didn't you use that date when you
`were forming your conclusions of obviousness?
` MR. DILLON: Objection. Form.
` THE WITNESS: I don't know.
`BY MR. MURPHY:
` Q Dr. Naughton, I'm handing you what's
`been previously marked as Exhibit 1005, and it's
`the same exhibit number in both proceedings.
` Do you recognize this document?
` A Yes.
` Q Okay, and what is this document?
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` Jeffrey F. Naughton, Ph.D.
` A It's a patent by Okamoto.
` Q Is this the Okamoto patent that you rely
`on in your declaration?
` A Yes.
` Q And in paragraph 87 of your declaration
`in the second sentence, you state that "Okamoto
`explains that a high-accuracy search can be
`realized by adding logic structures to queries."
` A I'm not there yet. This is paragraph
`87? Is that what you said?
` Q Paragraph 87. Let me know when you get
`there.
` A Okay, I'm there now.
` Q The second sentence of that paragraph,
`you refer to adding logic structures to queries.
`What do you mean by "logic structures" there?
` A Let me try to recall the sentence
`completely.
` I mean structural conditions.
` Q And "structural conditions" is a term
`used in Okamoto, right?
` A It uses terms similar to that. I don't
`know if he explicitly says "structural condition."
` Let's see. I believe so.
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` Jeffrey F. Naughton, Ph.D.
` Q And so a structural condition would be a
`logic structure?
` MR. DILLON: Objection. Form.
` THE WITNESS: Yes.
`BY MR. MURPHY:
` Q And in the same sentence you also
`mention documents which have individual logic
`elements. What are "logic elements"?
` A In the context of Okamoto, there would
`be most likely SGML elements, tags.
` Q And when you refer to "SGML elements,"
`do you mean the angle brackets?
` A The angle brackets to limit the
`elements.
` Q So the SGML element would be the angle
`of brackets and everything between those two
`brackets?
` A I would refer to that as an instance of
`an SGML element.
` Q Let's go to paragraph 88.
` A Yes.
` Q And in there you reproduce Figure 4 from
`Okamoto; is that right?
` A That's correct.
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` Jeffrey F. Naughton, Ph.D.
` Q And so in Figure 4 can you identify to
`me what a logic element would be?
` MR. DILLON: Objection. Form.
` THE WITNESS: These -- what am I
` saying? This is the DTD for a document,
` right?
`BY MR. MURPHY:
` Q Is that right? Is Figure 4 the DTD for
`a document?
` A Figure 4 is a DTD, document type
`definition.
` Q Does Figure 4 show a logic element?
` A I would put it -- I would say Figure 4
`shows -- I'm trying to phrase this exactly right.
`It, it shows things that can be used to construct
`logic elements, that can be used in logic
`elements.
` Q But does it show a logic element itself?
` MR. DILLON: Objection. Form.
` THE WITNESS: Let me refer back to
` the previous sentence to get the context.
` So I guess I never used "logic
` element." I use "logic structures." You can
` use these things like -- here we have author
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` Jeffrey F. Naughton, Ph.D.
` name, things like that, to build logic
` structures in queries.
`BY MR. MURPHY:
` Q So do I understand you right that Figure
`4 does not show a logic element then?
` A I'm not sure how I got into talking
`about logic elements. We have individual logic
`elements in the documents and logic structures in
`the search. These are not logic elements in the
`document.
` Q Agreed, because the document is depicted
`in Figure 5; is that right?
` A Yes.
` Q But my question is: Does Figure 4,
`which is a DTD file, have logic elements?
` A It describes logic elements that can
`appear in the document.
` Q And what is a logic element in Figure 5?
` MR. DILLON: Objection. Form.
` THE WITNESS: The tags in here are
` examples.
`BY MR. MURPHY:
` Q What do you mean by "tag"?
` A In this document?
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` Jeffrey F. Naughton, Ph.D.
` Q Yes. Let's use Figure 5 as an example.
`So in Figure 5 can you give me an example of a
`tag?
` A Left pointy bracket, author, close
`pointy bracket is an example.
` Q And if I refer to those as "angle
`brackets," would you understand what I'm referring
`to?
` A Yes.
` Q And so are you looking at the fourth
`angle bracket down, with author in between it, and
`another angle bracket to end it? Is that what
`you're saying is a tag?
` A That is a tag in this document, yes.
` Q And does that tag include the three what
`you would call I believe "tags" below it for name?
` A I would say the tag itself does not.
` Q And so four lines down, we have angle
`bracket, author, close bracket. The next line we
`have angle bracket, name. The next line down we
`have angle bracket, name. Next line down we have
`angle bracket, name.
` You would consider those to be four tags
`then?
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