UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`VMWare, INC.,
`Petitioner,
`v.
`INTELLECTUAL VENTURES I LLC,
`Patent Owner.
`____________________
`Case IPR2020-00470
`Patent 7,949,752
`____________________
`
`REMOTE DEPOSITION OF DARRELL LONG, Ph.D.
`October 28, 2020
`
`Reported by:
`MARY F. BOWMAN, RPR, CRR
`JOB NO. 330160
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`EX2019
`VMware v. IV
`IPR2020-00470
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________
`VMWare, INC.,
`Petitioner,
`v.
`INTELLECTUAL VENTURES I LLC,
`Patent Owner.
`____________________
`Case IPR2020-00470
`Patent 7,949,752
`____________________
`
`REMOTE DEPOSITION OF DARRELL LONG, Ph.D.
`October 28, 2020
`
`Reported by:
`MARY F. BOWMAN, RPR, CRR
`JOB NO. 330160
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`EX2019
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`IPR2020-00470
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`
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`2
`
`October 28, 2020
`12:00 p.m.
`
`Remote deposition of DARRELL LONG,
`Ph.D., held before Mary F. Bowman, a Registered
`Professional Reporter, Certified Realtime
`Reporter, and Notary Public of the State of New
`York.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`3
`
` APPEARANCES: (BY VIDEOCONFERENCE)
`
`WINSTON & STRAWN, LLP
`Attorneys for Petitioner
` 275 Middlefield Road, Suite 205
` Menlo Park, California 94025
`BY: LOUIS CAMPBELL, ESQ.
` MICHAEL RUECKHEIM, ESQ.
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`Attorneys for Patent Owner
` 1100 New York Ave, NW Suite 600
` Washington DC 20005
`BY: CHRISTOPHER R. O'BRIEN, ESQ.
` LESTIN KENTON, ESQ.
`
`Also Present:
` James Hietala, Intellectual Ventures
` Jillian Barricelli, Planet Depos Technician
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`4
`
` (Counsel agree to remote swearing
` of witness.)
`DARRELL LONG,
` called as a witness by the parties,
` having been duly sworn, testified as follows:
`EXAMINATION BY
`MR. O'BRIEN:
` Q. Dr. Long, could you please state your
`full name for the record.
` A. Excuse me, just a second. I'm having
`a little bit of video problems. I'm not sure why
`the monitor just went black.
` Darrell Don Earl Long.
` MR. O'BRIEN: Why don't we go off the
` record for a minute until the technical
` issues are resolved.
` (Pause)
` A. Darrell Don Earl Long, to answer your
`question.
` Q. And you understand that you are under
`oath today?
` A. I do.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`5
`
` Q. Is there any reason you cannot give
`truthful and complete testimony today?
` A. No.
` Q. I understand you've been deposed
`before. How many times?
` A. I don't know. I'd have to count.
`Let's -- more than a dozen.
` Q. OK. I know this is not your first
`deposition, but it's always good to go over some
`ground rules, especially since we are remote.
` Please provide verbal answers and
`let's try not to speak over each other. That way
`we can have a clear transcript.
` If you don't understand a
`question, please let me know and I'm happy to
`clarify.
` I'll try to take a break every
`hour or so, but if you need a break, please let me
`know. The only thing that I ask is that you
`complete any pending question before a break.
` A. Sounds good.
` Q. And you are represented today by
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`6
`
`counsel, right?
` A. I think so. I see Louis there.
`Again, this is a video deposition so I'm not sure
`how things work.
` Q. You are here on behalf of VMWare
`today, correct?
` A. Correct.
` Q. And you've been working with
`Mr. Campbell on this matter, is that correct?
` A. That's correct.
` Q. Just a little bit more before we get
`into the details given that today's deposition is
`remote.
` Could you please describe your
`environment?
` A. Sure. Hold on. This is my office.
`At my house. The top of the stairs.
` There is my scanner. There is my
`printer. There is the pictures of my wedding.
`There is the door that goes to the attic. There
`is a bunch of silly diplomas up there. The stairs
`are over here. My wife will come up later and
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`7
`
`bring me some coffee which will make me happy.
` That's the door to the bedroom
`and she is going to go close that and watch
`something on television while we talk.
` Q. Do you have any papers or documents
`with you?
` A. This (indicating).
` Q. And what is that?
` A. That is the binder, deposition binder
`Re: Dr. Darrell Long, Dr. Long Deposition. It has
`Exhibits 1005, 1001, 1018, 1019, 1020.
` I have a couple of squeezy
`things for my wrists. And my stapler. It is a
`blue stapler, not a red stapler which apparently
`is funny.
` My phone, which is on mute. And my
`wallet, my pen. For my dry eyes (indicating). And
`the dusty thing.
` I have a few tax papers over on the
`right here, so I have them behind a little scanner
`thing. But nothing of interest to you guys. All of
`that is off of my desk.
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`Conducted on October 28, 2020
`
`8
`
` Q. OK. And who provided you the binder?
` A. You know, I don't know. It came in
`the mail. I presume Louis and his team put it
`together. It came by Fed Ex the other day.
` Q. All right. And you understand you are
`here today to testify in an inter partes review
`proceeding between VMWare and Intellectual
`Ventures related to U.S. Patent 7,949,752, right?
` A. Correct.
` Q. And you're testifying today as a
`technical expert, right?
` A. Correct.
` Q. I just want to ask one quick question,
`the binder of documents we were just discussing,
`are there any notes in that binder?
` A. It is clean as the driven snow.
` Q. There is no annotation?
` A. None. Happy to send it to you when we
`are done.
` Q. OK. Thanks, we can follow up on that
`at the end.
` How did you become involved in this
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`Conducted on October 28, 2020
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`9
`
`proceeding?
` A. It's a long time ago. I mean, the way
`I am in all these things, some attorney sends me
`an e-mail says, hey, Dr. Long, do you know
`anything about this. In this case, I said yes, I
`do. And there you go. I don't think I have ever
`worked for Winston before.
` Q. Do you recall when you became
`involved?
` A. I can go check my e-mail if you want.
`Otherwise, no.
` Q. Within the last year or two?
` A. Yeah.
` Q. Are you serving as a technical expert
`on behalf of VMWare in any other proceedings?
` A. I guess I don't know the answer to
`that. These things -- for me, these things are
`complicated. There is a lot of patents and
`things. So I don't know the answer to that. I'm
`sorry.
` Q. Have you submitted or prepared any
`declarations on behalf of VMWare other than for
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`Conducted on October 28, 2020
`
`10
`
`this proceeding we are talking about today?
` A. For this -- so by this proceeding, you
`mean this particular patent and this IPR?
` Q. Correct.
` A. Ah, OK. Yes, we are working on some
`other things as well because apparently the
`litigation is complicated between the two parties.
` Q. OK. How did you prepare for today's
`deposition?
` A. I read a lot of stuff. And I met with
`Mr. Campbell -- was it two, three days ago -- by
`video, of course. And we talked, we talked it
`through.
` Q. Did you meet with anybody other than
`Mr. Campbell?
` A. I think there were some other people
`briefly on the call, but they kind of went mute
`and quiet pretty quickly.
` Q. Do you have any recollection as to who
`those individuals were?
` A. I don't.
` Hold on a second, I have to tell
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`Conducted on October 28, 2020
`
`11
`
`people to be quiet and leave me alone. There we
`go. There we go.
` All right.
` I do not. Again, I can go check
`my e-mails and see who was on the invite. But --
`do you want me to do that?
` Q. Not at this time. But are you aware
`of anybody that was not with the law firm of
`Winston & Strawn that was attending?
` A. As far as I know, they are all with
`Winston & Strawn. Best of my knowledge. It's
`virtual world. Maybe somebody was hiding in a
`corner, but I don't think so.
` Q. OK. Do you recall how long you met
`with counsel?
` A. Again, I would have to check my
`records, but let's say a couple of hours.
` Q. And earlier you had mentioned that you
`reviewed a lot of material or documents in
`preparation for today. Do you recall specifically
`what you reviewed?
` A. Since I don't get to have notes on a
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`Conducted on October 28, 2020
`
`12
`
`list, no, I don't. I can check -- I can -- again,
`I can check the folder on my computer and let you
`know if you would like.
` Q. Do you recall if you read the
`petition?
` A. The -- which petition? The original
`or the one that we -- Winston Strawn prepared or
`the response or which thing?
` Q. The original petition filed -- that
`was filed with your declaration at the --
` A. OK, this is Exhibit 1005?
` Q. It was filed with Exhibit 1005.
` A. So you're confusing me a little bit.
`This says Exhibit 1005 and it says -- is this the
`petition? I guess -- I'm sorry, this is my
`declaration, I'm sorry. Yes. I don't have a copy
`of it, but yes.
` Q. So you did review the petition?
` A. Yes.
` Q. Did you review the board's institution
`decision?
` A. I did.
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`Conducted on October 28, 2020
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`13
`
` Q. Since you have Exhibit 1005, I was
`going to introduce it electronically, but since
`you have a paper copy in front of you, we can use
`that for now.
` A. Whatever you find most convenient.
` (Exhibit 1005, Declaration of
` Darrell Long, Ph.D. marked for
` identification, as of this date.)
` A. Do you mind, for the sake of my wife,
`do you mind a virtual desktop? Can I do this?
` Q. Oh, that's fine with me.
` A. OK, great.
` We have a friend who is a watercolor
`artist and he sends these to me to try to cheer us
`during the plague.
` OK, I have in front of me right here.
` Q. Could you turn to the last page which
`is 81.
` A. Last page is pretty easy.
` Yes, I see it.
` Q. Is that your signature on page 81?
` A. That is.
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`Conducted on October 28, 2020
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`14
`
` Q. And when was the last time you
`reviewed this?
` A. Two days ago I read through it.
` Q. Just for the record, Exhibit 1005 is
`your declaration in this proceeding, right?
` A. Correct.
` Q. Is your declaration, Exhibit 1005,
`complete?
` A. A far as I know, it is complete. I
`don't see anything else missing.
` Q. Do you have any corrections to Exhibit
`1005?
` A. No.
` Q. And your declaration is accurate to
`the best of your knowledge, right?
` A. To the best of my knowledge, yes, sir.
` Q. And your declaration reflects all of
`your opinions regarding the '752 patent, right?
` A. Unless you ask me something that
`demands an opinion on the fly, yes, sir.
` Q. How did you prepare the declaration?
` A. I sent these guys a first draft. I'm
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`Conducted on October 28, 2020
`
`15
`
`a distinguished professor of engineering. So I
`write like an engineer. And as you know,
`attorneys write quite differently. So we worked
`together. You guys have to make sure you hit
`everything exactly right. You know how it goes.
` If I say something in a research paper,
`I say it once, I expect you to remember it. That's
`not how it goes here. So I worked with these
`gentlemen, and if there was any ladies in this case,
`to get it just right. But all the opinions
`contained in here are mine. I agree with them. I
`endorse them. I embrace them.
` Q. Do you recall how many hours, just
`approximately, it took to prepare the declaration?
` A. A bunch. Again, I would have to go
`look at my records.
` Q. In paragraph 7 of your declaration,
`you refer to your education. Correct?
` A. Let me get the paragraph 7, but
`probably right, yes.
` Q. You received your Ph.D. in 1998,
`right?
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
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`16
`
` A. No.
` Q. I thought --
` A. 1988. Gray in the beard.
` Q. Thank you.
` And you were a professor in 1998,
`correct?
` A. I was a professor before that. I was
`a professor in '88. So that I've been a professor
`ever since.
` Q. So you were a professor in the late
`'90s?
` A. Yes.
` Q. Do you recall in the 1996 to 1998 time
`frame what classes you taught?
` A. You know what? I can go look, it's on
`my CV. Would you like me to do that?
` Q. Do you have a -- do you have a paper
`copy of your CV which is Exhibit 1022?
` A. No, but I will in a second.
` (Exhibit 1022, Cumulative
` Biography of Darrell Long, Ph.D. marked
` for identification, as of this date.)
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`Conducted on October 28, 2020
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`17
`
` A. Darrell -- where is my CV?
` Q. Are you looking for a paper copy or an
`electronic copy?
` A. I don't keep a paper copy of a 60-page
`document on my desk.
` So I have it now. What did you
`want? You want '96, '97? I taught, in the fall,
`operating systems. I supervised eight, nine
`graduate students -- sorry. nine -- thirteen,
`eight, that's -- I supervised a bunch of graduate
`students. I taught a graduate class in
`cryptography, supervised a bunch more students,
`and I taught internet security and privacy to
`undergraduates.
` I was on sabbatical in the fall.
`What's that? I was at Stanford. Then I taught
`comparative programming languages, and then I
`taught advanced operating systems.
` Q. Just to make sure I understand, where
`in it Exhibit 1022 are you describing?
` A. Page 39.
` Q. Which portion of these were graduate
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`Conducted on October 28, 2020
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`18
`
`courses?
` A. Generally a thing with a number with a
`2 in it is a graduate course.
` So 204 would be graduate compiler design
`which was what I taught in the fall of 1995. And
`then, let's see, 221 is a graduate operating
`systems.
` So below 100 are freshmen, sophomore
`courses. 100s are senior and junior courses and 200
`and above are graduate courses.
` Q. So in the 1996 to 1998 time frame, you
`were predominantly teaching graduate courses,
`right?
` A. No. You will see that I taught
`undergraduate operating systems as well and I
`taught undergraduates internet security and
`privacy.
` Q. The classes you just listed, those are
`the only undergraduate courses you taught during
`that time, right?
` A. Through 1998, there is also
`comparative programming languages in winter of
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`Conducted on October 28, 2020
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`19
`
`1998.
` Q. I would like to switch back to your
`declaration, but before I do, I would ask that you
`not open any electronic documents without me
`asking to you do so.
` A. OK. But you asked for -- you asked
`for the CV. So that's what you got.
` Q. Yes, it has to be on a paper copy.
` A. Well, I could have printed it. Or you
`guys could have provided the documents that you
`wanted me to review. That's kind of the -- that's
`the danger of, you know, a remote deposition, and
`I apologize, but you ask a question, that's the
`only way it could be answered.
` Q. Well, I'll ask that you not open an
`electronic document again unless you're instructed
`to do so.
` A. OK. Well, when you asked me what I
`was doing 22 years ago...
` Q. If you could turn to paragraph 23 of
`your declaration, please.
` A. 23.
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`Conducted on October 28, 2020
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`20
`
` Q. Just let me know when you're there.
` A. I'm here.
` Q. From paragraph 23 through paragraph
`27, you present a summary of your understanding
`regarding anticipation, correct?
` A. Correct.
` Q. In your declaration, you did not
`provide any opinions regarding anticipation,
`correct?
` A. I would have to go through and read
`through declarations. It's February since I
`really studied it.
` Q. So you have not studied your
`declaration since February?
` A. I haven't studied it with an eye on
`whether I made an opinion about anticipation.
` Q. Do you recall presenting any opinions
`regarding anticipation in the declaration?
` A. I do not.
` Q. Can you please turn to paragraph 28 of
`your declaration.
` A. OK.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`21
`
` Q. In paragraph 28 through 33, you
`describe your understanding of obviousness,
`correct?
` A. Correct.
` Q. Paragraph 31, you state, "Any of the
`following rationales are acceptable justifications
`to conclude that a claim would have been obvious,"
`and then you list seven points. Correct?
` A. Correct.
` Q. Your understanding of obviousness from
`paragraphs 28 through 33, what you describe there
`you applied in reaching your opinions that you
`include in your declaration, right?
` A. Correct.
` Q. You did not apply any obviousness
`rationales not listed in these paragraphs,
`correct?
` A. Let me go back and look at the
`rationale, but I -- it's the usual stuff. No, I
`didn't.
` Q. If you could please turn to paragraph
`21 of your declaration.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
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`22
`
` A. OK.
` Q. In paragraph 21, you provide a
`definition of your opinion regarding the level of
`ordinary skill in the art for the '752 patent,
`correct?
` A. Correct.
` Q. And I believe you mentioned that you
`had read the institution decision, correct?
` A. Yes.
` Q. And do you recall that the board
`adopted this level of ordinary skill?
` A. I don't recall.
` Q. If you could turn to paragraph 34,
`please.
` A. OK.
` Q. And just one quick question before I
`ask about paragraph 34, I just want to confirm
`that in reaching your opinions regarding the '752
`patent in your declaration, you relied on the
`level of ordinary skill in the art you would find
`in paragraph 21, correct?
` A. Correct.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`23
`
` Q. Turning back to paragraph 34 and just
`let me know when you're there.
` A. Yeah, I am.
` Q. In paragraph 34, you refer to an agent
`called the AT&T Bell Labs surrogate bot. Do you
`see that?
` A. What line approximately?
` Q. It's about six lines from the bottom.
` A. OK, this is -- yes, I see it. The
`telescript agent and the AT&T bot.
` Q. What was the AT&T Bell Labs surrogate
`bot?
` A. Oh, gosh. Let me see if I can
`remember. This is a long time ago.
` I really don't recall what it did.
` Q. Did you ever work with anybody at Bell
`Labs?
` A. Yeah, I worked with Rob Pike and --
`oh, gosh, what was his name? I can see his face,
`he did the Venti file system.
` I worked with several people at
`Bell Labs. I was good friends with some of them.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`24
`
` Q. Were they folks with Ph.D.s or
`undergraduate degrees?
` A. Let's see. Rob has a Ph.D. but it's
`in astrophysics. Sean, I think just have a
`bachelor's degree.
` It's a mix. In computer science,
`you don't really need a Ph.D. if you're good.
` Q. And you mentioned Venti, is that
`right?
` A. V-E-N-T-I, it was a file system based
`on using cryptographic hashes to de-duplicate a
`storage system.
` Q. And who was the individual that you
`mentioned that created that, created Venti?
` A. That's the guy whose name is slipping
`my mind right now. There were several authors, I
`think Rob was on it, but the chief author, we
`would have to look it up, I'm sorry.
` Q. OK.
` A. It's very well known. It was in the
`first symposium on file and storage systems which
`I created back in '01, '02, something like that.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`25
`
` Q. The following sentence in paragraph 34
`refers to Etzioni internet softbots. Do you see
`that?
` A. Yeah.
` Q. What is or what are Etzioni's software
`bots?
` A. Etzioni's internet softbots are long
`gone, as are most of these things, because it is
`technology from so long ago.
` These were software agents that
`interacted with, as you see, things like archie,
`gopher, netfind, ftp and so forth. You can find
`the description of most of these in Sean's book.
` Q. And when you say Etzioni, who are you
`referring to there?
` A. Again, I don't have Sean's book in
`front of me right now. I apologize, do you want
`me to make --
` Q. That's -- if you don't recall --
` A. I don't recall it at this point.
`Usually, usually when we do this, you say, hey,
`here is this thing, I have five things in front of
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`26
`
`me.
` So my understanding is a deposition is
`not a memory test.
` Q. And when you say five things, what are
`those?
` A. We've looked -- we discussed this
`earlier in the deposition. 1005, 1001, 1018, 19
`and 20.
` Q. Could you please turn to paragraph 46
`of your declaration.
` A. OK.
` Q. In paragraph 46, this describes your
`understanding of claim construction, correct?
` A. Correct.
` Q. You did not offer any opinions
`regarding claim construction in your declaration,
`right?
` A. Right.
` Q. If you could jump back to paragraph
`41, please.
` A. OK.
` Q. Let me know when you're there.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`27
`
` A. I'm there.
` Q. In paragraph 41 of your declaration,
`you describe the '172 patent description of
`service resources, correct?
` A. '172?
` Q. '752.
` A. Let me make sure.
` Yes.
` Q. And in paragraph 47, you identify a
`number of descriptions and citations from the '752
`patent for the service resources, correct?
` A. No. Paragraph 47 says I understand
`that in prior district court PTAB proceedings...
` Q. My apologies. I'll ask my question
`again.
` In paragraph 41, you identify a number
`of descriptions and citations from the '752 patent
`for service resources, correct?
` A. I'm checking the numbers.
` Correct.
` Q. And the citation that you provide --
`let me rephrase that.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`28
`
` The quotations that you reproduced
`from the '752 patent in paragraph 41, the text of
`those quotations does not include the word
`"money," correct?
` A. The text of the quotations in
`paragraph 41 does not contain the word "money."
`Correct.
` Q. If you could turn to paragraph 43
`please, of your declaration.
` A. OK.
` Q. In paragraph 43 of your declaration,
`you discuss the '752 patent's description of
`service wrappers, correct?
` A. Substance-wise, yes.
` Q. And in paragraph 43, you state that --
`excuse me, let me rephrase that question.
` I just want to confirm your
`answer with respect to paragraph 43 regarding the
`discussion of service wrappers.
` Was your answer substance-wise,
`yes?
` A. Yes.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`29
`
` Q. OK. I just wanted to make sure I
`understand your answer.
` In paragraph 43, you state, "For
`example, service wrappers converted between a
`computer language or instruction set used with an
`agent server, 20, and the computer language or
`instruction set of the respective service, 24."
` Right?
` A. That's the text that I quoted from the
`'752. That's correct.
` Q. And that's describing an example of a
`service wrapper, right?
` A. That is the '752 example of a service
`wrapper.
` Q. If you could please jump forward to
`paragraph 129, please.
` A. OK.
` Q. And the second sentence of paragraph
`129 describes the '752 patent's description of
`service wrappers, correct?
` A. This is the line that begins, "The
`'752 patent described one possible
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`30
`
`implementation"?
` Q. In paragraph 129, the sentence
`starting, "The '752 patent describes service
`wrappers as..."?
` A. Oh, OK, I didn't see the quoted period
`here. OK.
` Yes.
` Q. In paragraph 129, you provide a number
`of quotes and citations to the '752 patent
`regarding service wrappers, right?
` A. Right.
` Q. In the quotations that you have
`reproduced in paragraph 129 and paragraph 43 of
`your declaration, does the word "money" appear?
` A. You are asking paragraph 41 and 129?
` Q. Paragraph 129 and 43.
` A. 129 and 43.
` I do not see the word "money."
` Q. If you could turn back to paragraph 70
`of your declaration, please.
` A. OK.
` Q. And the first sentence of paragraph
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`31
`
`70, with reference to Chow, states, "At least in
`1998 web servers were stateless and
`connectionless, so it was impossible for servers
`to maintains clients' states." Right?
` A. That is -- that was from the Chow
`patent. I think that I certainly knew of things
`that were stateful in 1998, but the Chow patents
`makes that statement.
` Q. The following sentence, could you read
`that aloud, please.
` A. "This meant that if a web page hosted
`on a web server were updated, there would be no
`way for client browsers who had previously
`downloaded the copy of that web page to know that
`the web page had been updated."
` Q. And then in paragraph 71, you state
`that Chow provided a solution to this problem.
` A. Right.
` Q. Right?
` And Chow's solution was to provide a
`revision manager, correct?
` A. Correct.
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`32
`
` Q. The Chow solution was not to make its
`remote HTTP servers stateful and
`connection-oriented, right?
` A. So Chow wasn't proposing an HTTP
`server. The idea was not to replace the HTTP
`server, but to add an additional functionality
`that would provide that stateful behavior.
` Q. So fair to say that Chow's remote HTTP
`servers were stateless and connectionless?
` A. No, not at all. Chow didn't modify
`the HTTP server. HTTP server would have come
`from -- let's see, in 1998, it probably would have
`come from Netscape. I'm not -- I don't remember
`right now if Hitachi was available at that time.
`And Chow is not proposing to modify that code base
`but instead to interpose a stateful revision
`manager.
` Q. So in Chow, the remote HTTP servers --
`let me rephrase that.
` So none of the HTTP servers of Chow
`operated in a system absent the revision manager
`where client browsers that had previously
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`33
`
`downloaded a copy of a web page would be aware
`that the page had been updated, right?
` A. Let's try that one again, that
`was particularly convoluted question. I'm sorry.
` Q. In Chow's description of its
`system without a revision manager -- are you with
`me?
` A. OK, we take out the revision manager,
`sure.
` Q. I just want to make sure I'm -- I
`understand Chow properly.
` What thing is that the remote --
`rather, the client browsers in that system without
`the revision manager would be unaware if the web
`page had been updated at the remote server, right?
` A. Absent the revision manager, they
`would not be notified that the web page had been
`modified. This is assuming that it's just the
`out-of-the-box Netscape server.
` Q. OK. And using Chow's revision
`manager, Chow doesn't describe that the remote
`HTTP server initiates a connection with a client,
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`Transcript of Darrell Long, Ph.D.
`Conducted on October 28, 2020
`
`34
`
`right?
` A. Not as I recall is the job of the
`revision manager.
` Q. So not the job of the remote HTTP
`server, right?
` A. That's not how the HTTP protocol
`works. There is the CCI call back which we can
`discuss later. I'm sure we will.
` Q. If we move to paragraph 76, please.
` A. OK.
` Q. You describe Chow's revision manager
`using a GET command to retrieve updated documents
`from the remote HTTP server, right?
` A. Right.
` Q. Further on in paragraph 76, you refer
`to Perl CGI scripts, is that right?
` A. In 76. Yup. That's the modified URL.
` Q.
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