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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT AND APPEAL BOARD
`________________________________________________________
`HTC CORPORATION AND HTC AMERICA,)
`INC., )
` )
` ) CASE IPR 2017-00857
` Petitioner, )
` ) Patent No. RE44,006 E
` )
` )
`KONINKLIJKE PHILIPS N.V., )
` )
` Patent Owner. )
` )
`________________________________________________________
` DEPOSITION UPON ORAL EXAMINATION BEFORE TRIAL
` OF
` JACOB WOBBROCK, Ph.D.
`_________________________________________________________
` 9:00 A.M.
` April 17, 2018
` 1201 Third Avenue, Suite 4900
` Seattle, Washington
`
`Reported By: Deanna M. Ellis, CCR No. 2511
`Job No:
`
`TSG Reporting - Worldwide - 877-702-9580
`
`Philips 2008
`HTC v. Philips
`IPR2017-00857
`
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT AND APPEAL BOARD
`________________________________________________________
`HTC CORPORATION AND HTC AMERICA,)
`INC., )
` )
` ) CASE IPR 2017-00857
` Petitioner, )
` ) Patent No. RE44,006 E
` )
` )
`KONINKLIJKE PHILIPS N.V., )
` )
` Patent Owner. )
` )
`________________________________________________________
` DEPOSITION UPON ORAL EXAMINATION BEFORE TRIAL
` OF
` JACOB WOBBROCK, Ph.D.
`_________________________________________________________
` 9:00 A.M.
` April 17, 2018
` 1201 Third Avenue, Suite 4900
` Seattle, Washington
`
`Reported By: Deanna M. Ellis, CCR No. 2511
`Job No:
`
`TSG Reporting - Worldwide - 877-702-9580
`
`Philips 2008
`HTC v. Philips
`IPR2017-00857
`
`
`
`Page 2
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` Wobbrock, Ph.D.
`
` April 17, 2018
` 9:00 a.m.
` Deposition of JACOB WOBBROCK, Ph.D.,
`held at the offices of Perkins Coie, LLP,
`1201 Third Avenue, Suite 4900, Seattle,
`Washington, before Deanna M. Ellis, CCR 2511
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` Wobbrock, Ph.D.
` APPEARANCES
`
`Fitzpatrick Cella Harper & Scinto
`Attorneys for Patent Owner
`975 F Street Northwest
`Washington, DC 20004
`
`BY: JUSTIN OLIVER, ESQ.
`
`Perkins Coie
`Attorneys for Petitioner
`11988 El Camino Real
`San Diego, CA 92130
`
`BY: RYAN HAWKINS, ESQ.
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` Wobbrock, Ph.D.
` INDEX
`
`EXAMINATIONS
` PAGE
`THE WITNESS: JACOB WOBBROCK, Ph.D.
`By Mr. Oliver ................................ 5
`By Mr. Hawkins ............................... 138
`
` EXHIBITS
`(No exhibits were marked.)
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` Wobbrock, Ph.D.
` JACOB WOBBROCK, Ph.D., Witness herein, having been
` duly sworn by the Certified Court Reporter, testified under
`oath as follows:
` EXAMINATION
` BY MR. OLIVER:
` Q. How are you today, Dr. Wobbrock?
` A. I'm good, thank you.
` How are you?
` Q. I'm fine, thanks.
` I'm just going to start with a little housekeeping.
` Do you understand that you're testifying under
` oath today?
` A. I do.
` Q. You understand what it means to testify under
` oath?
` A. I do.
` Q. Is there any reason you cannot give truthful
` or accurate answers today?
` A. No reason.
` Q. Okay. You're not taking any medication that
` may affect your ability to answer questions?
` A. No.
` Q. Over the course of the day, I'll ask you
` questions. I'll try to be clear. There might be
`
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` Wobbrock, Ph.D.
` occasions where my questions aren't clear. If there's
` an instance where my question's not clear, please let me
` know and I'll try and clarify.
` A. Um-hum.
` Q. If you don't indicate that the question was
` unclear, I'll assume that you understood the question;
` is that fair?
` A. That's fair.
` Q. Okay. Your counsel may make objections.
` Typically, it's an objection followed by one word. You
` understand that absent an objection based on privilege
` you'll be required to answer the question?
` A. I understand.
` Q. Okay. I'll try and take breaks about every
` hour or so. If you need to take a break before I've
` suggested one, please let me know. The only thing I ask
` is that if there's a question pending, that you answer
` it before we take the break; is that fair?
` A. Sure.
` Q. Okay. How did you prepare for your deposition
` today?
` A. I read -- re-read my declarations. I re-read
` the patents that are at issue. And I spent about four
` hours with counsel discussing the issues.
`
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` Wobbrock, Ph.D.
` Q. Okay. Now, was that just one meeting with
` counsel on this?
` A. It was.
` Q. Okay. With whom did you meet?
` A. Ryan Hawkins.
` Q. Anyone else?
` A. No.
` Q. All right. A little more housekeeping just to
` make the day go a little bit smoother.
` I'm going to give you a few documents here that
` have already been marked. The first document I'm going
` to give to you has already been marked as Exhibit 1001,
` and it's U.S. Reissued Patent 44,006.
` Do you recognize that document?
` A. I do.
` Q. Okay. The next document I'll hand to you has
` been already marked as Exhibit 1007. It's U.S. Patent
` 5,621,906, which I'll refer to as O'Neill.
` Do you recognize that document?
` A. Yes, I do.
` Q. The next document I'll hand you has been
` marked as Exhibit 1010. It is U.S Patent No. 6,006,227.
` I'll refer to this document as Freeman.
` Do you recognize that document?
`
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` Wobbrock, Ph.D.
` A. Yes, I do.
` Q. All right. The next document, Exhibit 1016,
` is your Declaration in Support of Petitioner's Reply to
` Patent Owner's Response.
` Do you recognize this document?
` A. Yes, I do.
` Q. Is that your declaration?
` A. Yes, it is.
` Q. That's your signature on the second page?
` A. Indeed, it is.
` Q. Okay. The last for now is Exhibit 1005, which
` is your initial declaration in this case.
` Do you recognize that document?
` A. I do, yes.
` Q. Okay.
` A. I have the first four items that you've shown
` me in this binder, which they're unmarked, just sort of
` with some tabs that make them a little easier to flip
` to, and three-hole punches that make them a little
` easier to turn. So if you don't mind, I may use this
` just for the sake of ease of use.
` Q. Certainly. May I just see it for a second?
` A. Of course.
` Q. Thanks.
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` Wobbrock, Ph.D.
` Okay. Can you turn to Paragraph 3 of your reply
` declaration.
` A. Yep. Okay.
` Q. In there you discuss the term "list;" is that
` correct?
` A. I do.
` Q. In the second sentence you say:
` Although list-type menus were common at
` the time of the invention, also common
` were menus of other shapes and types?
` Is that correct?
` A. Yes.
` Q. When you say "other shapes," what do you mean
` by other shapes than a list?
` A. Well, I give an example of a shape that's
` other than a list at the end of that paragraph, for
` example, the pie menu or circular menu, sometimes also
` called a radial menu, on the top of Page 2.
` Q. How are you defining the shape of a list?
` MR. HAWKINS: Objection; vague.
` A. Could you more specific?
` Q. Well, you say there could be other shapes, and
` I assume that means other shapes than the shape of a
` list; is that correct?
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` Wobbrock, Ph.D.
` A. I say:
` Also common were menus of other shapes
` and types, for example, pie or radial
` menus.
` Q. Okay. Does that refer to shapes other than
` the shape of a list?
` A. It does.
` Q. Okay. So what do you assume to be or what do
` you believe to be the shape of a list?
` A. Well, the list-type menus I refer to are
` the... Let's see. I don't have an example.
` I do here. We see some examples of list-type menus
` on Page 8 or Page 9 --
` Q. What's common about the shape of those -- or
` what's the assumption that you're making with respect to
` what the shape of such a list would be?
` MR. HAWKINS: Objection; foundation,
` assumes facts not in evidence.
` A. So these are -- in this case, these examples,
` Page 8 and 9, they're vertically arranged. They have a
` top and a bottom, and elements are stacked in these
` examples.
` Q. Are all lists vertically arranged?
` MR. HAWKINS: Objection; calls for
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` speculation.
` A. No, not necessarily. I was referring to the
` examples specifically on Pages 8 and 9.
` Q. Okay. So what would be a person of ordinary
` skill in the art's understanding of the shape of a list?
` MR. HAWKINS: Objection; beyond the
` scope.
` A. Yeah. So my analysis of a list in the case of
` what a person of ordinary skill in the art would regard
` was to say that there are menu designs that are clearly
` not lists, like the radial menu, circular in shape,
` where I give examples, as well, on Page 4 of animated,
` three-dimensional type menus that are not lists.
` Q. But you're saying that those have other
` shapes. So if we're going to say they have other
` shapes, I'm just trying to figure out what the shape of
` a list would be so that we can see what the differences
` are between the two.
` A. I have an --
` MR. HAWKINS: Objection;
` mischaracterizes his testimony. The paragraph
` specifically says menus of other shapes and types, and
` he's reiterated that several times, too.
` MR. OLIVER: The rules require an
`
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` Wobbrock, Ph.D.
` objection followed by one word. I'd like you to limit
` your objections to those stated in the rules.
` MR. HAWKINS: I -- what rule limits my
` objections to one word?
` MR. OLIVER: I'll pull the rule up at
` the next break.
` MR. HAWKINS: Okay.
` Q. You state in Paragraph 3 other shapes. So if
` there are shapes other than -- are you referring to
` shapes other than the shape of a list?
` A. In that paragraph I am.
` Q. Okay. So then my question is: What is the
` understood shape of a list?
` A. I haven't offered a definition of a list. I'm
` not prepared to give a comprehensive definition that
` would cover all types of lists. But I am prepared and
` have given examples of things that clearly are not
` lists, and they appear, as I said, on Page 2 and on Page
` 4 as examples.
` Q. All right. So taking the example on Page 2,
` what is it about the shape of that list -- or what is it
` about the shape of what's shown in the figure that is
` different than the shape of a list?
` A. In this case, we have a radial menu, which is
`
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` circular, and there's no stacking of the items in it,
` there's no list-like arrangement, and there's no top or
` bottom. But I'm not offering those characteristics as a
` comprehensive definition of a list, just characteristics
` of this particular menu.
` Q. If those are not characteristics that
` distinguish from a list, what are the characteristics
` that you relied on to distinguish this type of list --
` or this type of display from the shape of what would be
` understood as a list?
` A. So I said those are not -- I'm not offering
` those as comprehensive characteristics of a list.
` Q. You're not offering what as comprehensive
` characteristics of a list?
` A. So when I referred to the radial menu saying
` that the items aren't stacked, there's not a top or
` bottom, and so forth, those are characteristics of this
` pie menu that I used to opine that it's not -- would not
` be regarded as a list. But I am not offering a complete
` and full definition of what a list would be in that
` case.
` Q. Okay. You keep going back to stacked. Would
` your understanding of a list be that a list has to be
` stacked items?
`
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` A. I'm not saying a list has to be a set of
` stacked items. A list could be a set of stacked items.
` Q. Would the stacked items have to be linear?
` MR. HAWKINS: Objection; calls for
` speculation, beyond the scope.
` A. I haven't done that analysis.
` Q. Could a list be items that are arranged in a
` curved manner?
` MR. HAWKINS: Objection; beyond the
` scope, calls for speculation.
` A. Possibly.
` Q. Can a list be two columns?
` MR. HAWKINS: Same objections.
` A. I'd have to consider a more specific case to
` really offer an opinion. That's not an analysis I've
` done.
` Q. Do you have in mind a definition that a person
` of ordinary skill in the art would assign to the term
` list?
` A. No. That's not an analysis I've done. I
` think they could recognize when things are not lists.
` For example, the pie menu I've given on Page 2, that's
` different than saying that they would have a complete
` definition of a list in their mind.
`
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` Q. Some of the things you gave to distinguish the
` figure on Page 2 from a list is -- that it's radial and
` that it's not stacked; is that correct?
` A. I mentioned those as possible characteristics
` that one would recognize.
` Q. Okay. Is the term in the figure on Page 2
` "close" stacked over "save?"
` A. It's vertically above save. Whether one of
` ordinary skill in the art would consider that stacked, I
` can't really say.
` Q. If you can't say, how would you know whether
` or not a person of ordinary skill in the art would
` consider this a list?
` A. There are other characteristics to this menu
` that would suggest that it's not list-like.
` Q. What would those be?
` A. Well, I've mentioned them.
` Q. You said there's no beginning and end. Was
` that one of them?
` A. I believe that was right.
` Q. Why do you say there's no beginning or end on
` the Figure 2 menu?
` A. Because it's a circle --
` Q. Or Page 2, sorry.
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` A. Sorry, it's circle.
` Q. Okay. So if items are arranged in a circle,
` you would not consider them a list?
` A. I'm not prepared to make that generalization.
` Q. On what evidence did you rely to support your
` opinion in Paragraph 3 of your reply declaration?
` A. Can you repeat the question just to make sure
` I get it?
` Q. Sure.
` You conclude that list-type menus were common at
` the time of the invention. Also common were menus of
` other shapes and types, for example, pie and radial
` menus.
` A. Um-hum.
` Q. My question would be: What evidence did you
` rely upon to determine that a person of ordinary skill
` in the art would consider pie or radial menus to be
` different than list-shaped menus?
` MR. HAWKINS: Objection; misstates the
` testimony and the declaration.
` A. Well, the evidence that I relied on was my
` expertise in the history of the field and systems
` available at the time and before the time of the
` invention, the specific references that I include in my
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` Wobbrock, Ph.D.
` declaration here, and the example menus, both in my
` original declaration and in this response declaration.
` Q. Any specific documents?
` A. I cite to a few of them on Page 2 that you can
` see.
` Q. Those appear to be examples of other types of
` menus. I didn't see that those define the term "list"
` in any way.
` A. Okay. Is there a question?
` Q. Is there a document that you relied on to
` define the term "list?"
` A. Not specifically, no.
` I ascribed it. It's common understanding for one
` of ordinary skill at the time.
` Q. A grocery list could be a list; is that
` correct?
` A. In everyday language, sure.
` Q. Okay. If a grocery list was written in a
` circle, would it still be a grocery list?
` MR. HAWKINS: Objection; calls for,
` speculation, outside of the scope.
` A. I don't know. I haven't analyzed grocery
` lists as part of this work.
` Q. If you could look at the figure you provided
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` on Page 2 of your reply declaration, you refer to that
` as radial. When you say that what's shown is radial,
` are you referring to the actual text items or the
` graphics that surround them?
` A. The term "radial" for a menu like this is
` referring to the inside out, center out action by which
` these items are selected, typically.
` Q. If the graphics around them were rectangular
` instead of, you know, each pie shaped, would that then
` constitute a list?
` MR. HAWKINS: Objection; calls for
` speculation, beyond the scope.
` A. I don't know. I don't have an example of such
` a menu. I haven't done an analysis of one. I can't
` say.
` Q. Can you turn to Paragraph 4 of your reply
` declaration.
` A. Um-hum, yes.
` Q. There you point out that a preferred
` embodiment of the 006 Patent has a circular menu
` arrangement; is that correct?
` A. Yes. I say the circular --
` MR. HAWKINS: Objection; form, calls for
` a legal conclusion.
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` A. Yes. I say in Paragraph 4:
` The circular menu arrangement of Figure 2
` in the 006 Patent.
` Q. So when a person -- so would the existence of
` that example cause a person of ordinary skill in the art
` to understand that the menu as claimed in the 006 Patent
` need not be arranged in a linear manner?
` MR. HAWKINS: Objection. Same
` objections; calls for a legal conclusion, outside the
` scope.
` A. I'm not able to quite make sense of your
` question as stated. If you could repeat it or rephrase
` it, I'd appreciate it.
` Q. Well, you're suggesting -- well, let me
` rephrase that.
` You're stating that the presence of a circular
` menu in the 006 Patent would be one that a person of
` ordinary skill in the art would not regard as a list; is
` that correct?
` A. Yes. I say:
` Which has no defined beginning and end
` and which a POSITA would not regard as a
` list.
` Q. You state that a person of ordinary skill in
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` Wobbrock, Ph.D.
` the art would not consider that example a list because
` it doesn't have a defined beginning or end; is that
` correct?
` A. I do state that in my declaration.
` Q. Okay. What about the circularity of the
` arrangement? Is that another reason?
` A. I don't state that explicitly.
` Q. So based on your statement in claim 4 --
` A. Paragraph 4?
` Q. Excuse me, Paragraph 4, a person of ordinary
` skill in the art would not construe the claims that the
` 006 Patent as requiring a list of items having a defined
` beginning and end; is that correct? (Sic.)
` MR. HAWKINS: Objection; beyond the
` scope, vague.
` A. What I'm dealing with in Paragraph 4 in terms
` of the word "list" is from Philips construction, and the
` word appears in the construction offered by Philips. So
` a person of ordinary skill in the art would not confront
` that in the claim directly. I don't believe the word
` "list" is in the claim directly.
` Q. So what understanding of list -- let me
` rephrase that.
` Is there any understanding of list beyond what
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` Wobbrock, Ph.D.
` you've stated here, no defined beginning and end, that
` would prevent application of that term to what's shown
` in Figure 4 -- excuse me, Paragraph 4?
` MR. HAWKINS: Objection; misstates
` testimony.
` A. There well may be things that a person of
` ordinary skill would also consider besides a no defined
` beginning and end that would cause them to conclude that
` this is not a list arrangement.
` Q. What would those be?
` MR. HAWKINS: Objection; asked and
` answered.
` A. Yeah. I -- I've referred to a handful of
` things already. But I'd have to do that analysis
` further to provide you with an exhaustive answer of
` things they might consider.
` Q. Can you provide an example of one other thing?
` A. That's not an analysis I've done. It's enough
` that they would see there's no defined beginning and end
` to regard this design as not being a list. There may be
` other things they would consider. I'd have to think
` about that more.
` Q. What if a person of ordinary skill in the art
` encountered an inscription of an elliptical list? Would
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` Wobbrock, Ph.D.
` a person of ordinary skill in the art be able to
` understand what that means?
` MR. HAWKINS: Objection; calls for
` speculation.
` A. I'm not sure what you mean by an elliptical
` list exactly, so I couldn't say what they would say.
` Q. Well, what would you understand to be an
` elliptical list if someone said that to you?
` A. That's what I'm telling you. You've said it
` to me, and I don't know what you mean. I don't have an
` example of such a thing in front of me, so I don't know.
` Q. You can't provide any thought on what an
` elliptical list might be?
` A. Not off the top of my head, honestly, no.
` Q. Could what's shown in the figure -- in
` Paragraph 4 of your reply declaration be an elliptical
` list?
` MR. HAWKINS: Objection; beyond the
` scope.
` A. An "elliptical list" is not a term in the art.
` It's not a term I've ever heard or seen. It's not a
` term a person of ordinary skill in the art would have
` ever encountered. So I don't know.
` Q. So what's your understanding or would be the
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` Wobbrock, Ph.D.
` understanding of a person of ordinary skill in the art
` of an elliptical?
` A. Elliptical, as an adjective describing an
` ellipse, would be understood. And I refer to that in my
` original declaration and have a diagram and a few places
` of an ellipse. For example, on Page 96.
` Q. What would a person of ordinary skill in the
` art understand to be the definition of the term "list"?
` MR. HAWKINS: Objection; asked and
` answered.
` A. As I said before, I don't have a definition
` for you. That's not an analysis I performed. Offering
` a complete definition is a fairly large undertaking. So
` I'm not sure.
` Q. You indicated before that a list could include
` stacked items that have a beginning and end; is that
` correct?
` MR. HAWKINS: Objection; misstates
` testimony.
` A. A list could include items that are listed one
` above the other --
` Q. Okay.
` A. -- with a top and bottom. For example, that's
` an option, perhaps, for a list.
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` Wobbrock, Ph.D.
` Q. So with that understanding of list and the
` understanding of elliptical that you've already set
` forth in previous testimony, what would you understand
` to be an elliptical list?
` A. As I said, that's not something I've ever
` considered, heard, analyzed, regarded. I'm just not
` prepared to answer that.
` Q. Okay. Can you turn to Paragraph 7 of your
` reply declaration.
` A. Yes. Okay.
` Q. In Paragraph 7 you talk about the term
` "machine functions;" is that correct?
` A. Yes.
` Q. You state that you believe "machine functions"
` is too narrow of a term; is that correct?
` A. I say in Paragraph 7 that "machine functions"
` is too narrow.
` Q. You also discuss widgets as allowing a user to
` choose between either a command or a value; is that
` correct?
` A. I quote from Dr. Brad Myers' video -- a video
` publication called All the Widgets where he refers to
` quote, "An important class of widgets allows the user to
` choose one or more from a set of options, either to
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` Wobbrock, Ph.D.
` choose a command or a value," end quote.
` Q. Do widgets control computer functions?
` MR. HAWKINS: Objection; calls for
` speculation, outside the scope, vague.
` A. Not precisely. No, widgets do not control
` computer functions.
` Q. Can you turn to your original declaration,
` Exhibit 1005, Paragraph 54.
` A. Okay.
` Q. Starting on the second line there's a
` parenthetical that states:
` A user interface widget is a
` screen-based mechanism that can receive
` user input for the purpose of controlling
` a computer system.
` Is that correct?
` A. Yes, that's the parenthetical there in
` Paragraph 54.
` Q. So in what ways do widgets, as stated here,
` serve a purpose of controlling a computer system?
` MR. HAWKINS: Objection to form.
` A. Users control computer functions and can do so
` through widgets, among other methods.
` Q. So in that sense do widgets -- is the purpose
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` Wobbrock, Ph.D.
` of widgets controlling a computer system?
` A. Widgets play many functions allowing users to
` provide input to a system.
` Q. Okay. So why would you state that widgets are
` not used for controlling computer functions?
` MR. HAWKINS: Objection; misstates the
` testimony.
` A. I did not actually state that.
` MR. OLIVER: Can you read back that
` testimony.
` (Requested testimony read back.)
` Q. So you said not precisely, widgets do not
` control computer functions. What did you mean by that?
` A. Widgets don't control computer functions,
` users do --
` Q. Okay.
` A. -- as is clear in the quote here.
` Q. So users use widgets to control computer
` functions?
` A. Users control computer functions through a
` number of methods. Widgets can be one of them.
` Q. Okay. In Paragraph 7 of your reply
` declaration you refer to, in the sentence bridging Pages
` 4 and 5, menus having two primary purposes; to initiate
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` Wobbrock, Ph.D.
` a command or to set a value, correct?
` A. I want to make sure I'm looking in the same
` place to which you're referring.
` Are you quoting from the Brad Myers' quote or are
` you looking at something else?
` Q. No. I'm looking at the sentence that bridges
` Pages 4 and 5.
` A. Okay. I say:
` It was commonly understood that menus had
` two primary purposes; to initiate a
` command or to set value.
` Q. What does it mean "to set a value?"
` A. Menus, among other types of widgets, are
` commonly used to allow users to set a value, sometimes
` can be thought of setting a property of something. I
` give examples of color in a paint program or choosing a
` line thickness.
` Q. So let's take the example that you give of
` choosing a color in a paint program. You, for instance,
` give the example of selecting yellow, correct?
` A. I give that example, yes.
` Q. In discussing that example at Line 10 on Page
` 5 of your reply declaration you state that:
` Such a choice often places a checkmark
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` Wobbrock, Ph.D.
` next to the menu item but does not
` initiate any visible command or machine
` function from the user's point of view.
` Correct?
` A. That is an accurate reading of my quote there,
` yes.
` Q. So what do you mean by a visible command?
` A. When a command is triggered, for example, with
` a menu item, often, but not always, there's some kind of
` feedback for the user to understand that that command
` was initiated. Often, though, when setting a value of
` the kind like setting yellow, that kind of feedback is
` not provided because the user just changed the property
` of something.
` Q. What about the checkmark, would that be
` visible to the user?
` A. It might be. It depends on the design of the
` particular widget with which they're interacting whether
` that checkmark is used or visible.
` Q. What about beyond the user's view in the
` background does the selection of yellow perform an
` unseen underlying machine function?
` A. Well --
` MR. HAWKINS: Objection; calls for
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` speculation.
` A. I refer to this idea in my next sentence. I
` say:
` Of course, ultimately, everything and
` anything a computer does is executed in
` computer code and, in a purely technical
` sense, is a function carried out by a
` machine. But this is not how a POSITA
` would regard choosing a value from a
` menu.
` Q. Okay.
` A. Anymore than, for example, the user thinking
` about the state of the electric charge that they've just
` changed on their disc or in their memory, which is also
` behind the scenes.
` Q. So, then, there would be an underlying machine
` function that's performed when a user selects, for
` instance, yellow in a paint program?
` A. Well, for a computer to do anything, it
` functions as a machine.
` Q. Why do you refer to the user's point of view
` with respect to a machine function?
` A. Well, my analysis is what one of ordinary
` skill would understand. And the art at issue is user
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` interface technology. And the understanding of such
` technology is inherently tied
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