Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1351

Unredacted Claim Construction Brief by Samsung Electronics America, Inc.(a New York corporation), Samsung Electronics Co. Ltd., Samsung Telecommunications America, LLC(a Delaware limited liability company) re 1256 Order on Administrative Motion to File Under Seal, re (Dkt. No. 1183) (Attachments: # 1 Exhibit 2 to the Schmidt Declaration, # 2 Exhibit 4 to the Schmidt Declaration, # 3 Exhibit 9 to the Schmidt Declaration, # 4 Exhibit 10 to the Schmidt Declaration, # 5 Exhibit 11 to the Schmidt Declaration, # 6 Exhibit 12 to the Schmidt Declaration, # 7 Exhibit 13 to the Schmidt Declaration, # 8 Exhibit 14 to the Schmidt Declaration)(Maroulis, Victoria) (Filed on 7/26/2012) Modified text on 7/27/2012 (dhm, COURT STAFF).

EXHIBIT 2
FILED UNDER SEAL

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

2
3
4
5

APPLE INC., a California
corporation,

6

Plaintiff,
7

vs.

CASE NO. 11-CV-01846-LHK

8

9

10

11

SAMSUNG ELECTRONICS CO., LTD.,
A Korean business entity;
SAMSUNG ELECTRONICS AMERICA,
INC., a New York corporation;
SAMSUNG TELECOMMUNICATIONS
AMERICA, LLC, a Delaware
limited liability company,

12

13

Defendants.
_____________________________/

14
15
16
17

C O N F I D E N T I A L
A T T O R N E Y S' E Y E S O N L Y
O U T S I D E
C O U N S E L

18
19
20
21

VIDEOTAPED DEPOSITION OF RAVIN BALAKRISHNAN, Ph.D.
SAN FRANCISCO, CALIFORNIA
TUESDAY, AUGUST 16, 2011

22
23
24
25

BY: ANDREA M. IGNACIO HOWARD, CSR, RPR, CCRR, CLR
CSR LICENSE NO. 9830
JOB NO. 41176
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you just sort of turn it.

2

A

This way?

3

Q

Yeah.

4

A

Okay.

5

It may be a little difficult.

It just

flipped around and did something.

6

Q

If you hold it --

7

A

Touch sensor.

8
9
10

So tell me how you want it,

and then I'll -- I'll keep it that way and -Q

Hold it straight up like that, and then you

can --

11

A

12

if I can.

13

Q

14

we --

15

A

Let me just do this again.

16

Q

Okay.

17

All right.

Okay.

I'm gonna try and manipulate it,

So what -- so what are -- so what are

So you zoomed in on it first; right?

So is it fair to say that your opinion -- for

18

purposes of the gallery here, the -- the photograph

19

has to be zoomed in on it?

20

MR. MONACH:

Object to the form of the

21

question; incomplete hypothetical; inadequate

22

opportunity to examine the device; vague.

23

You can answer.

24

THE WITNESS:

25

In this particular example that

I'm gonna walk you through is an infringing example, I
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did zoom in.

2

in, I need to spend a bit more time making sure

3

whether it has to or not.

4

now on this device.

But whether or not it has to be zoomed

I have not done that right

5

MR. JOHNSON:

Okay.

6

THE WITNESS:

So, on this device, I went

7

through the -- the preamble.

It's clearly a

8

computer-implemented method.

It has a device with a

9

touchscreen display.

It is displaying right now a

10

first portion of an electronic document.

11

electronic document here happens to be a photograph or

12

an image, some kind of a picture of something.

13

MR. JOHNSON:

Q.

The

Is the electronic doc --

14

what -- what does an "electronic document" mean in the

15

context of this patent?

16

MR. MONACH:

Object to form to the extent

17

it's calling for a legal conclusion, but you can give

18

your views on that.

19

THE WITNESS:

In the context of this patent,

20

my understanding, having read the patent and the

21

claims, is the electronic document is some visual

22

representation on the screen that has a defined length

23

and a width, as an example, or defined set of

24

boundaries, because they may not have to be a

25

rectangular set of boundaries.
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2
3

MR. JOHNSON:

Q.

So can it -- it can be

anything with a defined length and width?
A

It could be any visually represented thing

4

with a defined boundary.

5

"boundaries," because length and width may connote a

6

rectangular thing.

7

necessarily.

8
9
10

Q

It may not be a rectangle,

So an electronic document is anything

that can be visually represented with a defined
boundary?

11
12

Okay.

I'd rather use the word

MR. MONACH:

Object to the form of the

question; object as calling for a legal conclusion.

13

THE WITNESS:

In the context of this patent

14

and the claims, reading the patent and the claims, I

15

would say that would be a -- my definition of an

16

electronic document would be something visually

17

representable on the screen that -- that has a defined

18

set of boundaries.

19

MR. JOHNSON:

Okay.

20

Q

How about the next limitation?

21

A

Okay.

So, as I said earlier, it's got a

22

first portion of an electronic document.

23

went through that.

24

Q

And -- and -- I'm sorry.

25

A

I'm sorry.
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Q

2

What does "first portion" mean?
MR. MONACH:

I'm going to object to the form

3

of the question to the extent it calls for a legal

4

conclusion.

5

THE WITNESS:

In -- in this particular

6

example, I would say the first portion is the -- the

7

portion of the image that we see displayed on the

8

screen, which I don't know how to describe this --

9

MR. JOHNSON:

Can you zoom in more on the

10

screen, just so we see it better.

11

good.

12

Yeah, okay.

That's

Thanks.
THE WITNESS:

Everything, including the

13

yellow blob in the middle and the blue stuff around

14

it.

15
16
17
18

MR. JOHNSON:

Q.

So it's everything that's

shown on the screen is the first portion?
A

Well, obviously, not this word "Samsung" and

things like that.

19

Q

Yeah.

20

A

The actual display, maybe if I -- without

21

touching it, if I can sort of indicate, you see the

22

bottom boundary there --

23

Q

Okay.

24

A

-- the top boundary, right boundary, and left

25

boundary?
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more likely, he is -- he is more than ordinary skill

2

in the art.

3

Q

Looking back at the Exhibit 21 and the -- the

4

non-zoomed in image we were just talking about, when

5

the entire image is displayed, I think you -- you

6

testified that that was the first portion; right?

7

A

When the full image is on screen?

8

Q

Yeah, just show it to the -- so the camera

9

can see it.

That's the one I'm talking about.

10

A

In -- in this example?

11

Q

In that example, right.

12

A

That would be a -- I guess, a first portion.

13

Q

Right.

14

A

Okay.

15

Q

So -- so a first portion can be the entire

16

image; right?

17
18

MR. MONACH:

Object to the form of the

question as calling for a legal conclusion.

19

THE WITNESS:

Yes, I would say so.

20

MR. JOHNSON:

Okay.

21

Q

Can the first portion and the electronic

22

document, as described in the claims of the '381

23

patent, be the same thing?

24
25

MR. MONACH:

Same objection; incomplete

hypothetical.
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2

THE WITNESS:
question.

3

I'm not sure I understand the

I'm sorry.

MR. JOHNSON:

Q.

So -- so, in that example,

4

which has gone dark now, in that example, what's --

5

what's the electronic document?

6

MR. MONACH:

Objection; incomplete

7

hypothetical; lack of foundation; calling for a new

8

opinion at the deposition.

9

THE WITNESS:

So I haven't thought about this

10

in -- in great detail, but sitting here right now,

11

looking at this, I would say the electronic document

12

would be the -- this image that's shown on the screen,

13

with the boundaries being the -- the edges of that

14

image, as I've just, kind of, outlined here.

15
16
17
18
19
20

MR. JOHNSON:
Q

All right.

And -- and for an electronic document, you

can have -A

Sorry.

I'll keep my finger on here so it

doesn't go away.
Q

Under your understanding of an electronic

21

document, an electronic document can have an internal

22

boundary; right?

23

MR. MONACH:

Object to the form of the

24

question as misstating the prior testimony and vague.

25

Object as calling for a legal conclusion and a new
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opinion.

2
3

THE WITNESS:

I don't think I talked about

internal boundary at all.

4

MR. JOHNSON:

5

Q

6

Okay.

boundary?

Can an electronic document have an internal

7

MR. MONACH:

8

MR. JOHNSON:

9
10

We talked about it in the

context of the contacts on the Tab 7 that had the -the list of names.

11
12

Object.

MR. MONACH:

Object to the form of the

question as vague, misstating the prior testimony.

13

MR. JOHNSON:

14

A

So do you understand my

question?

15

Q.

I -- I'm not 100 percent sure, because the

16

word "internal boundary" I don't think, has come up

17

yet, and if I look at the con- -- if I go back to the

18

contacts list discussions, if I recall correctly this

19

morning, the only thing that when we talked about the

20

boundary of the contact list, I mean, there's the

21

application that has more decorations around it,

22

but -- so it -- you know, maybe you can be more

23

specific about what you mean by -- when you say

24

"internal boundary."

25

Q

Okay.

So if we -- you can put that one down
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and pick up the tab -- this is Tab 7.

2

A

Okay.

3

Q

And if you go to the contacts --

4

A

Yes, I'm at the contacts.

5

Q

-- location, right.

6

If you -- so my question is:

I think earlier

7

you said, use a pen, if you want to use a pen, can you

8

draw -- just can you just sort of show the camera what

9

the electronic document is in that context?

10

MR. MONACH:

Object to the form of the

11

question; calls for a legal conclusion, incomplete

12

hypothetical; asking for a new opinion.

13
14

THE WITNESS:

Okay.

Let me just refresh

myself on what this thing does here.

15

So I think I -- I believe I testified that

16

the electronic document -- this would be a portion of

17

the electronic document, because the entirety is not

18

shown.

19

in this rectangular column, and right now it's showing

20

me a partial --

It's will be this, this stuff that's displayed

21

MR. JOHNSON:

Yeah.

22

THE WITNESS:

-- amount.

23

MR. JOHNSON:

Q.

24
25

So there -- there are

pieces above the F and below the T?
A

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MR. MONACH:

2

MR. JOHNSON:

3
4
5

A

Object to form.
Q.

Or maybe not below it.

Yeah, there is stuff above the F and below

the T, yes.
Q

Okay.

So all I was asking was, you can have

6

an electronic document that has an internal boundary

7

within a screen; right?

8
9
10

MR. MONACH:
question as vague.

Objection; calls for a legal

conclusion.

11
12

Object to the form of the

THE WITNESS:

So I -- I'm not -- again, I'm

still not sure what you mean by "internal."

It --

13

MR. JOHNSON:

I'm --

14

THE WITNESS:

Are you saying that this is the

15

boundary of the electronic document?

16
17
18
19
20

MR. JOHNSON:
Q

Yeah.

I just meant that that's internal because

it's -- it's located within the middle of the screen?
A

So in that -- that boundary doesn't match the

edge of the screen --

21

Q

Exactly.

22

A

-- is what you're -- is that what you're

23

saying?

24

Q

Exactly.

25

A

Sure, the boundary of the document doesn't
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2

have to align with the screen.
Q

So you can have -- you can have the edge of

3

the boundary be something other than the edge of the

4

screen?

5

MR. MONACH:

6

MR. JOHNSON:

7
8
9
10

thing.
A

Objection; vague.
I think we're saying the same

I'm just -- I'm really bad with trying to -I want to make sure I say the right thing

with my understanding of what you're saying, too.
Q

So all I'm saying is, under your view of an

11

electronic document, an electronic document can have a

12

boundary that is internal to the screen or, you know,

13

doesn't have to be at the edge of the screen --

14

MR. MONACH:

15

MR. JOHNSON:

16

MR. MONACH:

17

Objection; form.
Q.

-- right?

Objection; calling for a legal

conclusion; asked and answered.

18

You can do it again.

19

THE WITNESS:

So as I answered earlier, and

20

my opinion is that the boundary of the electronic

21

document, in this case, this -- this edge is one

22

boundary of it, does not have to match the edge of the

23

screen, yes.

24
25

MR. JOHNSON:
Q

Okay.

So just, during the lunch, I had the guys
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just print up a sheet of paper with some squares on it

2

for me.

3

quadrants that are labeled 1 to 36 on here are the

4

entire -- that's this -- that's the screen of the

5

display.

6
7

A

So if you imagine, sir, that the -- the

So the whole -- the big rectangular is the

screen?

8

Q

Right.

9

A

Okay.

10

Q

So you can have an electronic document that

11

consists of smaller grids within the screen; right?

12

MR. MONACH:

Object to the form of the

13

question; calling for a legal conclusion; incomplete

14

hypothetical; asking for a new opinion.

15

THE WITNESS:

It would depend on what one

16

considers to be the electronic document.

17

one of these, let me call it sub rectangles that you

18

can label with numbers.

19

of them.

It could be

It could be some combination

It --

20

MR. JOHNSON:

Right.

21

THE WITNESS:

-- really depends on -- depends

22

on how, you know, you want to put the boundary around

23

it.

24
25

MR. JOHNSON:

Q.

So you could draw a

boundary, hypothetically, around squares 15, 16, 17,
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18, 21 and 22, 23 and 24?

2

A

Say -- sorry.

3

Q

22, 23, and 24.

4

A

So kind of like this?

5

Q

Yeah, go ahead and draw it.

6

MR. MONACH:

15, 16, 17, 18, 21?

Object to the -- object to the

7

form of the question as vague and ambiguous;

8

incomplete hypothetical.

9
10

MR. JOHNSON:

Q.

Make it a little more

noticeable for me.

11

A

We've got black lines around it.

12

Q

Yeah, okay.

13
14
15

So that could be an electronic document;
right?
A

Depend --

16

MR. MONACH:

17

THE WITNESS:

18

Depending on the context, depending on the

19

Same objection.
Sorry.

I jumped in there.

application, it could be.

20

MR. JOHNSON:

Okay.

21

THE WITNESS:

Or some other collection.

22

MR. JOHNSON:

Q.

23

It's not limited to that;

right?

24

A

I would not say it's limited.

25

Q

So it could be also a -- a six-by-six grid or
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a two-by-two grid?

2

MR. MONACH:

3

MR. JOHNSON:

4

Q.

-- or even a three-by-three

grid, I guess --

5

MR. MONACH:

6

MR. JOHNSON:

7

MR. MONACH:

8

Same --

Same objection.
Q.

-- right?

Vague and ambiguous; incomplete

hypothetical.

9

THE WITNESS:

Again, it would depend on the

10

def- -- you know, how -- whoever is being the

11

application, what they consider to be the document --

12

to be the extent of the document, yes.

13
14

MR. JOHNSON:

MR. MONACH:
before.

17
18

MR. JOHNSON:
Q

22

MR. JOHNSON:

25

Okay.

Does the grid need to be a rectangle?
MR. MONACH:

24

Depending on the context, it --

it could take on different forms.

21

23

Objection; same objection as

Also, misstates the prior testimony.
THE WITNESS:

19
20

Under your view, though, it

could be those, those grids; right?

15
16

Q.

Same objection.
Strike it.

Let me ask it

again.
Q

Does -- would the grid need to be a rectangle

in order for it to be an electronic document?
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MR. MONACH:

2

THE WITNESS:

Same objection.
Well, I think the electronic

3

document doesn't have to be anything to do with the

4

grid.

It --

5

MR. JOHNSON:

Okay.

6

THE WITNESS:

-- it's any visual thing with

7

defined boundaries --

8

MR. JOHNSON:

So -- so it --

9

THE WITNESS:

-- by my definition of it.

10

MR. JOHNSON:

Q.

Could -- if you -- if you

11

drew lines around squares one, two, and eight, for

12

example --

13
14
15

A

One, two, and eight.

So this kind of, I

guess, inverted L?
Q

Yeah.

16

Could that be an electronic document?

17

MR. MONACH:

Objection; vague; incomplete

18

hypothetical; calling for a legal conclusion and a new

19

opinion.

20

THE WITNESS:

So to the extent that I haven't

21

considered this, this style of odd-shaped documents

22

prior to coming here today, just thinking on the fly

23

here, a -- based on my understanding of, you know,

24

boundaries, that wouldn't -- would satisfy the notion

25

of a boundary, again, depending on the context of the
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application and what a document means in that context.

2

MR. JOHNSON:

Q.

If -- going back to the

3

original two-by-four rectangle of 15, 16, 17, 18, 21,

4

22, 23, 24, if you look at that, is it fair to say

5

that this line right here is an edge of the electronic

6

document?

7

A

The line --

8

MR. MONACH:

9

Hang on a second.

10

THE WITNESS:

11

MR. MONACH:

Object.

I'm sorry.
Objection; vague and ambiguous;

12

incomplete hypothetical; calling for a legal

13

conclusion and a new opinion.

14
15

THE WITNESS:

this prior to this, you putting this in front of me.

16
17

So, again, I haven't considered

Thinking on the fly here, so you're saying
this line -- the vertical line between --

18

MR. JOHNSON:

Since the witness is pointing,

19

I just want to make sure you get what he's pointing

20

to.

21

Yeah.

22

THE WITNESS:

23

The vertical line between 14

and 15, and 20 and 21, here, this --

24

Q

That -- that's right, yeah.

25

A

-- line.
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Given this hypothetical scenario, where

2

you're saying the -- this two -- I'm sorry --

3

two-by-four grid of elements -- rectangle is an

4

electronic document in this hypothetical scenario,

5

that would be indeed, I guess, one boundary one

6

edge --

7

Q

Okay.

8

A

-- of that.

9

Q

So let's just label that "edge" for me, just

10

so I can keep track of it after the deposition.

11

Just --

12

A

What do you want me to call it?

13

Q

Just call it "edge," and then maybe put it

14

down at the bottom and draw an arrow down to the line,

15

or something.

16

A

Like this?

17

Q

Yeah.

18

A

Okay.

19

Q

Okay.

And then, is it fair to say that

20

the -- the -- the Blocks 14 and 20 are an area beyond

21

the edge --

22

MR. MONACH:

23

MR. JOHNSON:

24
25

Same -Q.

-- of the electronic

document?
MR. MONACH:

Same objection.

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THE WITNESS:

So, again, considering this for

2

the first time here, I haven't thought this in detail,

3

if, in this hypothetical scenario, the document is

4

this two-by-four grid, labelled 15, 16, 17, 18, 21,

5

22, 23, 24, if that is the document, then anything

6

beyond that edge would be an area outside the document

7

beyond the edge of the document.

8

So given those hypotheticals, area 14 and 20

9

would be beyond the edge of the document, given that

10

scenario.

11

MR. JOHNSON:

Okay.

12

Q

So can you just label that "beyond the edge"?

13

A

How -- just label each one of these?

14

Q

Yeah, or just draw -- however you want.

15

A

Well, we're getting a lot of drawings on this

16
17
18

thing, so I don't know.
Q

"Beyond."

Speaking of which, let me just mark the --

the grid as Exhibit 104.

19

A

Put it on the bottom?

20

Q

Thanks.

21
22
23

(Phone marked Balakrishnan Exhibit 104
for identification.)
MR. JOHNSON:

Q.

Can you look at the Galaxy

24

Tab, which is Exhibit 101, and pull up for me the

25

contacts application.
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A

Okay.

2

Q

And I noticed, in your declaration, you did

3

not include this particular application on -- as one

4

that infringes the '381 patent, so the question is:

5

Why?

Why not?

6

MR. MONACH:

Object to the form of the

7

question, and if -- if your answer would -- I'll

8

instruct the witness not to disclose any

9

communications with counsel, other than facts and

10

assumptions that he relied on in forming his opinion.

11

THE WITNESS:

So, at the time of writing the

12

report, I was, as I testified earlier, the -- the -- I

13

was -- I was told that Apple was alleging these four

14

devices and the particular applications, and they

15

were -- as far as I know, were not alleging the

16

contacts list on the Galaxy Tab 10.1, so I did not

17

analyze that in great detail.

18

So if you want me to go through this right

19

now, I'm happy to walk you through this and see which

20

portions of the claims I'm having -- which are not, if

21

you want me to do that.

22
23
24
25

MR. JOHNSON:

Q.

So you haven't -- you

haven't done that analysis before today?
A

I haven't done it in detail sufficiently,

just talk about it right off the cuff, without walking
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through.
Q

Okay.

So when -- when Apple gave you the

3

roadmap to look at what was allegedly infringing,

4

contacts in the Galaxy tab wasn't included?

5

MR. MONACH:

6

THE WITNESS:

Object to form.
I -- yes, the -- the contacts

7

on the Galaxy Tab was not one of those I was -- it was

8

not one of those that I was told was being alleged to

9

infringe.

10
11
12
13
14
15
16
17
18

MR. JOHNSON:
Q

Okay.

So take a look at contacts in the Galaxy Tab

and -- and now that you have it, tell me -A

Sorry.

It just keeps flipping.

If you give

me a second here.
Q

-- why it doesn't infringe.
MR. MONACH:

Object to the form of the

question.
THE WITNESS:

Okay, so I'm just gonna walk

19

through the claims here and try to match it up and

20

tell you where -- where it matches and where it

21

doesn't match, if that's okay.

22

So the Galaxy tab, as we've gone through it

23

before, has a complete computer-implemented method

24

that's in the preamble, compromising a device with a

25

touchscreen display.

So we've already established

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that the device has a touchscreen display.

2

clearly displays a first portion of an electronic

3

document in this example right here that I've got.

4

I've got an electronic document, which is this

5

contacts list.

6
7

MR. JOHNSON:

Q.

It -- it

Would you mind just showing

the camera.

8

A

So I'm walking through this, too, so --

9

Q

Yeah, that's fine.

10

A

-- I may have to go back and forth.

11

Q

Yeah, that's fine.

12

A

So you got it --

13

Q

So where -- where is the electronic document

14
15

there?
A

Okay.

16

MR. MONACH:

17

THE WITNESS:

18

MR. MONACH:

Hang on a second.
Sorry.
Object to the form of the

19

question; calling for a legal conclusion; asking for a

20

new opinion at the deposition; and vague and

21

ambiguous.

22

THE WITNESS:

23

the fly.

24

So, again, I'm doing this on

great detail before.

25

I haven't -- haven't thought about this in

So the electronic document here is this list
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of -- of contact information on, you know, Big Bird,

2

Genie, Playhouse, and so forth; and what's shown on

3

the display right now, the -- the electronic document

4

is -- well, it just stopped here.

5

with the elements that, starting with a B, all the way

6

down to Tommy Bahama at the bottom, so that would be

7

the -- the first por- -- the portion of the electronic

8

document.

It has -- starts

9

MR. JOHNSON:

Okay.

10

THE WITNESS:

Not the entirety.

11

Clearly

there's more stuff.

12

MR. JOHNSON:

Okay.

13

THE WITNESS:

There appears to be more stuff

14

on the two -- beyond the two edge -- boundaries.

15
16
17

MR. JOHNSON:
Q

Okay.

But the area to the right of the edge is not

part of the electronic document?

18

MR. MONACH:

19

THE WITNESS:

So --

20

MR. JOHNSON:

Q.

21

Same objection.

So this, this area right

over here, is not part of the electronic document?

22

MR. MONACH:

23

THE WITNESS:

Same objection.
So in this example

24

application -- in this application, looking at it just

25

right now at this deposition, I would say the
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electronic document does not include the -- the area

2

right here.

3

MR. JOHNSON:

Okay.

4

Q

Okay.

How about the next limitation?

5

A

Okay.

So I think I already said first

6

portion of the electronic document.

7

The next limitation, detecting a movement of

8

an object on any other touchscreen display.

9

again, I'm gonna put my finger down, which would be

So,

10

the object, and it's on or near -- it clearly detects

11

movement of the object on or near the touchscreen

12

display.

13

In response to -- then, the next element

14

would be "In response to detecting the movement,

15

translating the electronic document displayed on the

16

touchscreen display in a first direction to display a

17

second portion of the electronic document, wherein the

18

secret portion is different from the first portion."

19

So let me go back to where I was here.

20

think it was something like that, with a B, I think it

21

had Tommy Bahama on the bottom there.

22

was before.

23

the movement, and I'm gonna move it down a little bit,

24

and that would give me the -- translating the

25

electronic document in a first direction display a

I

That's where I

So I'm gonna put my finger down, which is

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2

second portion, where the second portion is different.
So the second portion here now has an A on

3

the top part of the portion that's displayed on the

4

screen, and on the bottom, instead of Tommy Bahama on

5

the -- the first portion now has Missy, Missy

6

Buttersworth at the bottom, so that's a different

7

portion of the document.

8
9

So now we can go on.

So it says, in

response -- the next element says -- of the claim says

10

"In response to an edge of the electronic document

11

being reached, while translating the electronic

12

document in the first direction, so while the doc --

13

while the object is still detected on or near the

14

touchscreen display, displaying an area beyond the

15

edge of the document."

16

So I'm gonna continue moving, and now I see

17

that it stops.

18

stops at the word "14 contacts" that is part of the

19

document.

20

doesn't seem to go beyond the edge, so it doesn't seem

21

to meet this thing of going beyond the edge and

22

displaying an area beyond the edge of that document.

23

The document there got the As in it

It stops there.

It doesn't go -- it

And so that -- I don't know what the number

24

of this element is, but that -- that part of the claim

25

is not -- it doesn't appear to be met in this
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