throbber
FRANCES HARDER
`
`April 24, 2014
`
`U095
`
`to on this.
`
`U095
`
`U09“
`
`U099
`
`U09fl
`
`U09%
`
`U09”
`
`U093
`
`H09M-
`
`Q.
`
`And when they say a one—by—one tuck stitch,
`
`what does that refer to?
`
`A.
`
`One by one is usually referring to a knit.
`
`So i'm not sure if they're talking about a knit.
`
`Maybe the tuck stitch has got elasticity in it so it
`
`would stretch. We don't know that.
`
`Q.
`
`What do you mean by —— what does it mean by
`
`"l by l"? What does that refer to?
`
`H09% ;
`
`A. Well,
`
`a knitted garment,
`
`like a T—shirt,
`
`is
`
`U09“ L
`
`usually referred to as a one—by—one knit.
`
`You can
`
`U09“ L
`
`have —— a rib would probably be two by two.
`
`So
`
`H09% ;
`
`you've got di
`
`fereni
`
`iypes of terminology depending
`
`H09” ;
`
`on what kind of knit
`
`the woven fabric is made from.
`
`H093 i
`
`Q.
`
`For the ignorant, what is it about
`
`the knit
`
`HD9% ;
`
`that makes it one by one instead of two by one or
`
`HJQW ;
`
`three by one?
`
`UJOM ;
`
`A. Well, you've probably —— you've seen
`
`HJQM ;
`
`yourself when you wear T—shirts,
`
`some of them
`
`1LW04
`
`U10”
`
`H10”
`
`Ufl0W
`
`U10“
`
`U10”
`
`stretch more than others. And :'m sure you've got a
`
`sweater that's made with a ribbing on the bottom,
`
`and you'l’
`
`find that the ribbing holds better than
`
`the actual upper part,
`
`so the ribbing is a di
`
`ferent
`
`type of knit.
`
`So yo; wi‘l
`
`find that, you know,
`
`there are different term’no'ogies when it comes to
`
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`
`DMC Exhibit 2018_064
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`Uflflfl
`
`whether it's woven or knits.
`
`U105
`
`H103
`
`U103
`
`H105
`
`U10“
`
`N109
`
`Hfl0%
`
`H10“
`
`Hfl&% ;
`
`Q.
`
`Let's go back to Column 3 that —— where we
`
`were just reading about the tuck stitch because
`
`maybe we can understand some more. Actually, be:
`
`i do that,
`
`this -- this exhibit here,
`
`iarder
`
`Deposition Exhibit 4,
`
`th’s ‘s one of the documents
`
`that you reviewed in —— in preparing your
`
`declaration; correct?
`
`A.
`
`Q.
`
`Correct.
`
`Okay. That's one o:
`
`the documents you
`
`Hfl0fl
`
`;
`
`reviewed in preparing to give your opinion in this
`
`ILW54 ;
`
`case?
`
`1kw54Z_
`
`Hfl&% ;
`
`Ar
`
`Q.
`
`Correct.
`
`Okay.
`
`How much time did you spend
`
`11:10:56
`
`:-
`
`reviewing this --
`
`Hfl&% ;
`
`Hfl&% ;
`
`MR. L4CHL% Tfikz Objection.
`
`Form.
`
`Q.
`
`3Y Mx. BOLLACK:
`
`—— this particular
`
`HJLW ;
`
`exhibit, Deposition 4?
`
`Hfltm ;
`
`A.
`
`I can't recall.
`
`1kU04
`
`UJLW
`
`H1?”
`
`Uflkfl
`
`UJPM
`
`Hflkfi
`
`.
`
`.
`
`.
`
`More than an hour?
`
`I —— I don't know.
`
`: mean, we've had a
`
`5 conversations.
`
`_ can't add it up.
`
`Okay.
`
`It could be less than an hour?
`
`_.
`
`fiCHRfi “Ax: Objection.
`
`Torm.
`
`”
`
`1
`
`TN%SS:
`
`: don't know at this stage.
`
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`
`DMC Exhibit 2018_065
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`not prepared to give you an estimate o:
`
`how long
`
`reviewed it for.
`
`Q.
`
`BY MR. POLLACK: More or less than 30
`
`minutes?
`
`MR. L+CHLfi ”%R: Objection.
`
`Form.
`
`Q.
`
`A.
`
`3Y Mk. BOLLACK:
`
`You don't know?
`
`I —— to give you an estimate,
`
`I would say
`
`_
`
`3ut_ _
`
`_
`
`That's all I'm asking for is an estimate.
`
`Yeah_
`
`dQn't kngw ——
`
`okay,
`
`More than 30 minutes?
`
`Yeah_
`
`Okay_
`
`T would think SO.
`
`Q A Q A
`
`.
`
`Q A Q A
`
`Q.
`
`Is it more than an hour that you spent on
`
`Weposition Exhibit 4?
`
`UflkW
`
`Hit”
`
`Hflkfl
`
`Hflkfi
`
`Hflkfi
`
`Uflk%
`
`HJLN
`
`11:11:30
`
`11:11:33
`
`11:11:33
`
`11:11:33
`
`HJLB
`
`HflL% ;
`
`11:11:37
`
`HJLW
`
`UHF”
`
`Hflkfi
`
`Uflkfl
`
`;
`
`'
`
`Hfltn ;
`
`A.
`
`Maybe if you add up the five minu'
`
`Hit“
`
`11:11:48
`
`H11“
`
`Hflkfl
`
`Hflkfl
`
`Uflkfl
`
`and five minutes there,
`
`then maybe, yes, i
`
`an hour_
`
`Q.
`
`Okay. But not much over an hour?
`
`MR. L%CHL% ”%R: Objection.
`
`Form. Asked and
`
`answered.
`
`THfi W ”
`
`1
`
`:
`
`: wouldn't —— I
`
`think that's as
`
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`66
`
`DMC Exhibit 2018_066
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`ILU54
`
`HflL%
`
`HJZW
`
`Ufll%
`
`U110
`
`Ufllm
`
`U11”
`
`U115
`
`:
`
`l‘m going to go with that.
`
`l don't know.
`
`Q.
`
`BY MR. POLLACK: Okay. Going to Column 3
`
`in Deposition Exhibit 4,
`
`line 38, it says there,
`
`"This,
`
`the lxl alternating tuck stitch pattern
`
`increases the modulus ol
`
`the fabric.
`
`Qy increasing
`
`the modulus of the "abric,
`
`the fabric stretches less
`
`and controls more. Preferably,
`
`the modulus of the
`
`tabric is increased between about
`
`6% and about
`
`lO%,
`
`HJZW
`
`more pre‘erab‘y about 8%.
`
`Increasing the modulus by
`
`HflZ% ;
`
`about
`
`8% provides a desirable compromise between
`
`Hfllw ;
`
`control and comfort."
`
`HJZM ;
`
`HJZU l
`
`HJZB ;
`
`A.
`
`Q.
`
`aid
`
`—— did I read that correctly?
`
`Correct.
`
`Okay.
`
`{aving now read that section,
`
`UflZ% L
`
`does -— does that give you the intormat on you need
`
`Hfllw ;
`
`to understand whether or not the control area is
`
`1LD54Z_
`
`expansible?
`
`HflZ% l
`
`A.
`
`i would say that the control area is
`
`Hfllfi
`
`;
`
`expandible.
`
`I
`
`think it said it earlier on it would
`
`Ufllw
`
`11:13:04
`
`H11%
`
`U11”
`
`Uflim
`
`U113
`
`expand with the wearer.
`
`Q.
`
`Uh—huh. Okay.
`
`And let me ask you a further question,
`
`then.
`
`Is the control area expansible to cover and
`
`"t over a growing abdomen during d’ ”erent stages
`
`of pregnancy?
`
`CENTEXT LEGAL SERVICES
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`67
`
`DMC Exhibit 2018_067
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`HfllM-
`
`H133
`
`1
`
`2
`
`A.
`
`I
`
`think it states in here that it would.
`
`But let me —— where are you referring back to?
`
`Hfliw 3
`
`Q.
`
`Column 3. This is the control area in the
`
`Hflifi
`
`H158
`
`Hflifi
`
`4
`
`5
`
`6
`
`high—waist brief.
`
`A.
`
`Okay.
`
`Can you tell me what your question
`
`is again?
`
`Hfli% 7
`
`MR. POLLACK: Court reporter, if you could
`
`H13”
`
`ILU54
`
`8
`
`9
`
`ILB54 LO
`
`Hfl&B
`
`1
`
`Hflim ;2
`
`Hfliw L3
`
`Hflifl
`
`;4
`
`Hflifl-;5
`
`Hfli% ;6
`
`repeat the question.
`
`(Record was read by the Deposition
`
`O”"icer as follows:
`
`"Q.
`
`Is the control area
`
`expansible to cover and "t over a
`
`growing abdomen during d‘""erent
`
`stages of pregnancy?")
`
`” % W TN%SS:
`
`I couldn't tell you unless
`
`Hfli% ;7
`
`Q.
`
`BY MR. POLLACK: Okay.
`
`"‘ you could turn
`
`Hflifl L8
`
`to Column 9 o‘ Weposition Exhibit 4,
`
`the 3rowder
`
`Hfl6W ;9
`
`patent.
`
`Do you see where it says,
`
`"%k £3 SUMMARY OF
`
`11:16:12 20
`
`'l'H+'.
`
`NV4.N'l' ON"?
`
`U169 21
`
`H16” 22
`
`A_
`
`Q.
`
`yes_
`
`Okay. Under that, it says —— i'm going to
`
`H166 23
`
`read i- into -he record.
`
`"It is the object o:
`
`the
`
`Hfléfi 24
`
`present invention to provide an improved seamless
`
`Hflfifl 25
`
`garmen: having areas o: additional control that are
`
`CENTEXT LEGAL SERVICES
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`68
`
`DMC Exhibit 2018_068
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`1L%24
`
`11:16:29
`
`Hflfiw
`
`Hflfiw
`
`U163
`
`U163
`
`U165
`
`HJEU
`
`1kW%4
`
`shaped to a "ect specifically chosen areas o:
`
`body _ "
`
`A.
`
`Q.
`
`Do you see that?
`
`Correct.
`
`Okay.
`
`Is it correct that —— is my
`
`understanding correct that the idea of a control
`
`area is to sguee e in or hold in areas of the body
`
`that are surrounded by the control area?
`
`M&. L%CHL% T%R: Objection.
`
`Form.
`
`Hfléfi
`
`;
`
`Tlfi W TN%SS: Control can mean in di””erent
`
`H16” ;
`
`ways,
`
`so you could have something with a lot oi
`
`Hfléfl
`
`Hflfifi
`
`Hflfifl
`
`;
`
`L
`
`;
`
`control and it would hold you in,
`
`like the Spanx.
`
`Control could be comfort,
`
`so you would want to wear
`
`something that was comfortable to the body and that
`
`Hfliw ;
`
`you would want
`
`to —— want to wear that would give
`
`1LW04Z_
`
`and also control.
`
`Hfl%% ;
`
`Q.
`
`BY MR. POLLACK: Wasn't
`
`the idea of
`
`HJTW ;
`
`control —— there's a garment that here in the U.S.
`
`HHTB ;
`
`we call it a girdle; right?
`
`11:17:12
`
`HJTB
`
`H1TW
`
`HflTB
`
`HHTB
`
`U173
`
`A_
`
`Uh—huh_
`
`.
`
`Is the idea of control
`
`in this patent
`
`the idea of a girdle?
`
`.. W%C{L% 3%R: Objection.
`
`Form.
`
`“ fl
`
`TN%SS:
`
`"Girdle" is an old word.
`
`.
`
`I
`
`MR. POLLACK: Okay.
`
`CENTEXT LEGAL SERVICES
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`69
`
`DMC Exhibit 2018_069
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`UflT%
`
`N1?”
`
`1kW34
`
`Ufllfi
`
`NH?”
`
`U1?”
`
`uirm
`
`H1?“
`
`ILW44
`
`A.
`
`3ut girdles, it would depend on, you know,
`
`the amoun- o e'asticity in ‘t and how much comfort
`
`you want and, o: course, again,
`
`the sizing o:
`
`the
`
`garment and the size o:
`
`the person wearing it.
`
`O.
`
`Okay. But you've —— you've reviewed the
`
`3rowder reference?
`
`A_
`
`Q.
`
`R;ght_
`
`is a concept behind the Browder reference
`
`to get
`
`the same kind o: control tqat a girdle
`
`11:17:47
`
`:_
`
`prgvides?
`
`HJTW ;
`
`Hflffl
`
`;
`
`Mk. L4CHL% Tfikz Objection.
`
`Form.
`
`Tia W TN%SS: Well,
`
`like a bra, you can have a
`
`ILW54 L
`
`bra that's controlled, but it's also comfortable --
`
`11I17I54
`
`Ufllfi
`
`Hflffi
`
`I-
`
`L
`
`;
`
`Q.
`
`A.
`
`BY MR. POLLACK: Uh-huh.
`
`—— and it expands depending on whether you
`
`want
`
`to run or walk or be active.
`
`So, again, it
`
`Hfl&m ;
`
`depends on what activity and what it's for and how
`
`Hfl&% ;
`
`it's been engineered, what the technical designer
`
`Hfl&% ;
`
`did to derive and decide on that type o
`
`”abric
`
`uA&m
`
`used,
`
`1LWfl4
`
`H1&W
`
`Ufl&m
`
`Hfl&W
`
`Ufl&B
`
`Q.
`
`Okay. Well, you've read 3rowder. What is
`
`3rowder's idea o: control?
`
`..
`
`.%CHL% T%R: Objection.
`
`Form.
`
`“ 4
`
`TN%SS:
`
`I'm not here to translate the
`
`so I'm not prepared to give you that.
`
`CENTEXT LEGAL SERVICES
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`70
`
`DMC Exhibit 2018_070
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`Ufl&%
`
`Ufl&N
`
`HJ&%
`
`Ufl&M
`
`Ufl&%
`
`Ufl&“
`
`Ufl&%
`
`UJ&W
`
`Ufl&fl
`
`Q.
`
`BY MR. POLLACK:
`
`You don't know, as you sit
`
`here today?
`
`A.
`
`I'm not here today to give you translations
`
`from patents.
`
`I'm not an expert on legalese.
`
`So
`
`fi'm here to give you an idea o: what a person o;
`
`ordinary interest would understand from taking the
`
`information that's already available and out
`
`in the
`
`market and making it into a garment that they could
`
`wear when they were pregnant.
`
`Hfl&% ;
`
`Q.
`
`Yeah, okay. Well,
`
`:'m not asking about any
`
`Hfl&W ;
`
`legal terms.
`
`:'m asking what is —— as you just
`
`Hfl&% ;
`
`described, what a person o: ordinary skill would
`
`Hfl9W ;
`
`understand.
`
`Hfl9m ;
`
`What would they understand from what
`
`Hfl9% ’
`
`Qrowder has written here about control? What's the
`
`Hfl9% ;
`
`purpose of control
`
`in the —— in the Browder patent?
`
`Hfl9% ;
`
`A4 Well, an ordinary person WOJld not be
`
`H199 ;
`
`reading through patents.
`
`They would be looking at
`
`H196 ;
`
`garments out
`
`in the market and they would be
`
`Ufl9W
`
`U19”
`
`H19N
`
`ILW24
`
`Ufl9N
`
`U493
`
`analyzing them and making decisions as to whether
`
`they could actually make this themselves.
`
`So
`
`think that reading through documents on patents is
`
`not something that an ordinary person would be --
`
`would do or be expected to do.
`
`Q.
`
`Prior to working on this case, have you --
`
`CENTEXT LEGAL SERVICES
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`71
`
`DMC Exhibit 2018_071
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U193
`
`HJQM
`
`1kW34
`
`n19%
`
`U19”
`
`HJQM
`
`HJQM
`
`Hfl9U
`
`U195
`
`had you ever read through patents?
`
`_
`
`.
`
`,
`
`.
`
`_
`
`.
`
`No_
`
`That's not something you've done be:
`
`NO_
`
`You've never been involved in a patent case
`
`NO_
`
`Looking further down in Column 2 under the
`
`brie: summary of the invention,
`
`the next paragraph
`
`Hfl9% ;
`
`says, "It is another object of the present invention
`
`HQQW ;
`
`to provide such a garment that has a control area
`
`U20% '
`
`‘ormed by an alternating tJCk stitch pattern in the
`
`HJOW L
`
`undergarment."
`
`H2&H ;
`
`HQOH ;
`
`HQQQ ;
`
`A.
`
`Q.
`
`Do you see that?
`
`Correct.
`
`Okay.
`
`So the alternating tuck stitch
`
`U206 L
`
`pattern,
`
`is it an important part of what 3rowder's
`
`naum ;
`
`H299 ;
`
`_.
`
`1 “£3: Objection to form.
`
`H209
`
`HQQH
`
`H203
`
`H20M-
`
`11:20:25
`
`U205
`
`” fl
`
`”
`
`1
`
`:
`
`: wouldn't know that.
`
`Q.
`
`i
`
`_
`
`.
`
`LACK: Without seeing the
`
`garment, you can't tell?
`
`A,
`
`Q.
`
`_\1O _
`
`Even reading this patent, you can't tell?
`
`CENTEXT LEGAL SERVICES
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`72
`
`DMC Exhibit 2018_072
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U203
`
`H203
`
`H20%
`
`UJOH
`
`U20%
`
`UQOW
`
`H20M-
`
`HJQW
`
`Hflkm
`
`A.
`
`No,
`
`: can't tell.
`
`So,
`
`to me,
`
`this sounds
`
`kind o: weird, but
`
`I assume it worked.
`
`Q.
`
`Let me go down a little bit ”urLher.
`
`“o
`
`yo; see the last paragraph under "%< £3 SUMMARY OF
`
`THfi
`
`NVfiNT ON" around line 24?
`
`it says, "in
`
`accordance with the present invention,
`
`a circular
`
`knitting machine knits a singular tubular blank
`
`including a tubular <nit body."
`
`Do you see that?
`
`Hflkw ;
`
`A.
`
`Correct.
`
`HQLW ;
`
`Q. What's that referring to? What's a
`
`ILZHM ;
`
`circular knitting machine?
`
`Hflkfi
`
`L
`
`A.
`
`Circular knitting machine is a machine
`
`H2t% ;
`
`that's made up ot a tibe and you've got
`
`the —— ii
`
`Hflkm i
`
`you know what —— knitting is normally straight when
`
`HQLB ;
`
`you can think o: your mother knitting.
`
`A tubular
`
`HJLB ;
`
`knit is made oi —— comprises ot
`
`the needles going in
`
`HJLW ;
`
`a tibe and knitting in a tube.
`
`So the garment is
`
`Hfltn ;
`
`knitted, and then the jabric is in a big tube and
`
`Uflkfi
`
`Hit”
`
`H2?“
`
`ILH34
`
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`
`U21“
`
`then it's cut depending on what —— what you want
`
`to
`
`do as far as the Cjt is concerned.
`
`So that's
`
`normally known as tubular knit.
`
`The tubular knit can be all kinds o: sizes.
`
`So you might have a T—shirt that's tubular knit with
`
`no side seams.
`
`Or
`
`in some o:
`
`these cases with
`
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`
`DMC Exhibit 2018_073
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U2L%
`
`U31“
`
`Hit“
`
`“it”
`
`Uflkfl
`
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`
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`
`Uflkfi
`
`Hit“
`
`maternity clothing,
`
`they have no seams,
`
`so it's a
`
`tubular knit.
`
`Q.
`
`is that something that's also referred to
`
`as a Santoni machine?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Tha-'s -he maker.
`
`Tha-'s -he maker?
`
`So it depends on who is making it.
`
`Okay. That's their trademark you mean?
`
`A. Well, it's like saying a Mercedes or, you
`
`Hflkfl
`
`;
`
`know, Toyota.
`
`HQZW ;
`
`Q.
`
`Okay.
`
`Do you know —— do you know when
`
`HJZM ;
`
`Santoni machines were introduced to the market?
`
`1LBfi4Z_
`
`A4
`
`i have no idea.
`
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`
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`
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`
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`
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`
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`
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`
`Okay. Was it —— was it in the —— the late
`
`: don't know when.
`
`Not something you looked into?
`
`it something that's —— you've been in
`
`'
`
`’
`
`field since the l970s;
`
`is that fair?
`
`In the l970s, were you familiar
`
`with —— were there circular knitting machines?
`
`A. Absolutely.
`
`Q.
`
`There were?
`
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`
`DMC Exhibit 2018_074
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`ILE24
`
`UJZN
`
`U21”
`
`H21“
`
`U22“
`
`U21“
`
`U215
`
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`
`U21”
`
`Al
`
`My "rst job I ever had was a knitwear
`
`company, and it was circular knits.
`
`Huge machines.
`
`Q.
`
`Okay. Reading further in the paragraph,
`
`the next sentence says,
`
`"The tubular knit body
`
`contains an elastomeric yarn added along designated
`
`courses.
`
`The tension o:
`
`the elastomeric yarn is
`
`constant throughout
`
`the entire garment. However,
`
`in
`
`the area of the garment where increased control is
`
`desired,
`
`a ’X' alternating tuck stitch pattern is
`
`Hfliw ;
`
`used.
`
`The 'X'
`
`tuck stitch tightens the fabric and
`
`U21% ’
`
`’ncreases the modulus o:
`
`the elastomeric yarn.
`
`Hflim ;
`
`Thus,
`
`the stitch pattern decreases the amount o:
`
`Hflim ;
`
`stretch in the fabric."
`
`Hflifi
`
`;
`
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`
`Hfliw ;
`
`Hflifl
`
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`
`11:23:32
`
`;
`
`L
`
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`
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`
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`
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`
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`
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`
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`
`rid
`
`read that correctly?
`
`Correct.
`
`Okay. Does that —— does that show that the
`
`A.
`
`Q.
`
`idea in the Browder patent is to use this tuck
`
`stitch to tighten the area where the control area is
`
`"Sound?
`
`A.
`
`To add more control.
`
`it sounds like they
`
`are needing to add more control.
`
`Q.
`
`What do you mean by "more control"?
`
`not sure what that term means.
`
`A, Well,
`
`just translating what they've said
`
`here,
`
`increase the —— the s
`
`itch pattern decreases
`
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`
`DMC Exhibit 2018_075
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`Ufilw
`
`the amount of stre
`
`U213
`
`Hflifi
`
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`
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`
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`
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`
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`
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`
`Q.
`
`A.
`
`Q.
`
`To make 1
`
`-re-ch less?
`
`So make 1
`
`-re-ch less.
`
`Okay.
`
`"
`
`‘ers to something modulus.
`
`What is that?
`
`A.
`
`I'm not quite sure in this particular case,
`
`modulus, what that means.
`
`.
`
`.
`
`.
`
`Okay. Have you heard that term before?
`
`Not really.
`
`I've heard of modular, but not
`
`What is a modula [sf
`
`:?
`
`. Modular can be in d’ ”erent terminologies.
`
`HZAB ;
`
`You can have modular manufacturing and modular
`
`H2¢6 ;
`
`pieces and --
`
`H2¢B ;
`
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`
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`
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`
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`
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`
`Oh. Modular,
`
`a—r --
`
`Yeah.
`
`—— at the end?
`
`Yeah.
`
`Okay.
`
`So it's modular, m—o—d—u—l—a—r?
`
`A. Modular; right.
`
`Q.
`
`Yes. Okay. Our accents are both
`
`'
`
`“erent_
`
`A.
`
`Q.
`
`Yes .
`
`“e both have regional accents.
`
`By the way, you said something about
`
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`
`DMC Exhibit 2018_076
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U2¢%
`
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`
`HQAM
`
`HJAB
`
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`
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`
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`
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`
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`
`3rowder being weird. What did —— what did you mean
`
`by that?
`
`A, Well,
`
`just the terminologies o: using this
`
`particular tuck stitch. Maybe that's something that
`
`I haven‘: had the pleasure o: seeing, but usi
`
`tuck stitch on top o: a knf-Led iubular knit —
`
`it might be included, but it sounds like it was
`
`added atter. %ut
`
`—— and WithOJt seeing a garment,
`
`it's very hard to make a judgment exactly what it
`
`u2&m '
`
`=s_
`
`u2&m ;
`
`_
`
`Qkay_
`
`Hfliw ;
`
`A.
`
`‘
`
`saw it in front o_ me,
`
`: could
`
`H2i% ;
`
`probably translate it quite easily. Oftentimes
`
`H219 ;
`
`anyway,
`
`from what I've seen on my short term oi
`
`Hflim ;
`
`being on these patent legalese,
`
`sometimes people
`
`HQEW ;
`
`writing them up are not really ‘amiliar with the
`
`Hflifl
`
`;
`
`industry as such.
`
`H2i% L
`
`Q.
`
`Do you know who Browder is?
`
`Do you know
`
`Haim ;
`
`him or...?
`
`11:25:28
`
`11:25:28
`
`H25”
`
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`
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`
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`
`A_
`
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`
`.
`
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`
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`
`NQ_
`
`That was a "no"?
`
`Jhat was a "no."
`
`For the record. Yeah, okay.
`
`"’ you could —— i: you could turn to Figure
`
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`
`DMC Exhibit 2018_077
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`N25”
`
`U25”
`
`Ufliw
`
`Uflifl
`
`U255
`
`U255
`
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`
`U26%
`
`UJGW
`
`Deposition Exhibit 4,
`
`the 3rowder patent.
`
`A.
`
`Q.
`
`Figure ll? Okay.
`
`Okay.
`
`Figure 1’, "'m correct,
`
`is the --
`
`that is the maternity brie‘?
`
`A.
`
`Q.
`
`Correct.
`
`Okay. Does —— does that maternity brie:
`
`have a belly panel that encircles a wearer's torso
`
`just beneath the wearer's breas: area?
`
`A.
`
`it looks like a brief lo me.
`
`So I'm not
`
`Hfléw ;
`
`sure what your terminology as far as —— what you're
`
`U269 l
`
`asking me is, what —— does it look like it's --
`
`Hflfifl
`
`11:26:22
`
`;
`
`j_
`
`H263 ;
`
`could you rephrase that one.
`
`Q_
`
`yes _
`
`Does —— does the maternity brie: in Figure
`
`H2&M-;
`
`ll encircle —— have an upper edge o: a belly panel
`
`H2&% ;
`
`that encircles a wearer's torso just beneath the
`
`U26@ l
`
`wearer's breast area?
`
`1k%%4Z_
`
`Al
`
`it's hard to tell because there's no
`
`H26% ’
`
`re‘erence o: where —— the breast area here.
`
`You see
`
`U26“
`
`U263
`
`H3?”
`
`N26”
`
`UJTW
`
`1FW04
`
`tha: —— the bulge of :he stomach, and it looks like
`
`it tapers down. And that's normally where a
`
`pregnant woman's breast —— a pregnant woman's belly
`
`or abdomen would grow is below the breast. But
`
`without seeing wh r
`
`th r i r nc
`
`o:
`
`the breast is
`
`on this, it's very hard to tell where it finishes or
`
`CENTEXT LEGAL SERVICES
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`
`DMC Exhibit 2018_078
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`UQTW
`
`where it starts.
`
`ILN08
`
`H2?“
`
`U2?”
`
`UQTQ
`
`nary
`
`ILN54
`
`H2T%
`
`U2?”
`
`Q.
`
`Okay.
`
`Jhis term "control area" tha'
`
`Browder keeps using,
`
`is that a —— is that a‘
`
`that you heard before this case?
`
`A.
`
`Q_
`
`.A.
`
`Q.
`
`Control area?
`
`yeah_
`
`"n reteredce to what?
`
`So garments or clothing.
`
`A, Well, certainly with active sportswear
`
`H2&% ;
`
`and —- you talk about control panels.
`
`I work with
`
`H2&% ;
`
`other maternity companies,
`
`so they also talk about
`
`H2&n ;
`
`the comfort and contro'
`
`‘or the wearer.
`
`H2&B ;
`
`Q.
`
`What does control area mean in those
`
`H2&D ;
`
`contexts?
`
`H2&W ;
`
`Al Well,
`
`I
`
`think it depends on what it is
`
`H2&B ;
`
`you're making.
`
`So control could be —— for active
`
`H2&% ;
`
`sportswear, it could be contro'
`
`‘or the panels on
`
`H2&% ;
`
`the side of
`
`-he legs of sportswear or it could be
`
`H2&M ;
`
`control for the underbra.
`
`It depends on, you know,
`
`U2&%
`
`U2&%
`
`H28“
`
`U2&B
`
`U2&%
`
`U3&”
`
`what —— what it is you need it for.
`
`Q.
`
`Okay.
`
`You said you worked for other
`
`maternity companies. What other maternity companies
`
`are you working for now?
`
`A.
`
`At
`
`the moment,
`
`:'m not —— I CODSJlt, and we
`
`have -- through ry organization, Fashion Business,
`
`CENTEXT LEGAL SERVICES
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`79
`
`DMC Exhibit 2018_079
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U2&M-
`
`U2&W
`
`n2&%
`
`U2&%
`
`UQQW
`
`U29%
`
`U29%
`
`11:29:12
`
`U299
`
`Incorporated, we consult with companies who start
`
`their own business.
`
`Q,
`
`A.
`
`Qkay_
`
`And two o:
`
`the companies that joined my
`
`organization in the early 2000s, both o:
`
`them had
`
`maternity wear companies.
`
`Q.
`
`Can you tell me which two companies those
`
`are?
`
`A, Well,
`
`they're both defunct now. They're
`
`U299 L
`
`not working.
`
`H290 ;
`
`H296 ;
`
`Q_
`
`A.
`
`Okay.
`
`But
`
`they both went on to have babies and
`
`U29W '
`
`‘ound that
`
`the industry was too stress
`
`ul
`
`"or
`
`them.
`
`H29N ;
`
`One of them was Layette.
`
`The other one,
`
`I
`
`thin<,
`
`H293 ;
`
`was the name o_ the owner, which was Rosanna.
`
`Bu‘
`
`H29% ;
`
`we're still good friends.
`
`: could easily get
`
`tha'
`
`112932 ’
`
`i11‘ornmr:’on, knit...
`
`H293 ;
`
`Q.
`
`Okay. But what —— what kind of products
`
`H29M-;
`
`did Layette make or wish to make?
`
`U29%
`
`U29“
`
`11229244
`
`U295
`
`11:29:48
`
`U39”
`
`A. Actually,
`
`they made a lot of —— they made
`
`maternity wear,
`
`so it was di ”erent
`
`items, separate
`
`items _
`
`Q.
`
`Did that include maternity pants?
`
`.
`
`.
`
`Oh, yeah, uh—huh, 1-: did.
`
`Do you know whether they made any maternity
`
`CENTEXT LEGAL SERVICES
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`
`80
`
`DMC Exhibit 2018_080
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U293
`
`U29%
`
`H30W
`
`U30%
`
`U30%
`
`nsam
`
`U30U
`
`H308
`
`U308
`
`H3&M ;
`
`11:30:16
`
`Z-
`
`H3&m ;
`
`pants that went up to just below the breast area?
`
`A. Actually,
`
`I was looking at some --
`
`him yesterday, and : did see —— we looked at --
`
`reviewed some o: his pants, and they have a tubular
`
`knit on the top that can be pulled up or rolled
`
`down,
`
`Q.
`
`Okay. Did they —— did they go up to the
`
`breast area?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`They went over the abdomen.
`
`Went over the abdomen?
`
`Uh-huh .
`
`Okay. What about up to the —— to the
`
`H3&w ;
`
`breasts?
`
`H3&m ;
`
`A, Well,
`
`that —— the pregnant abdomen usually
`
`H30fl
`
`;
`
`ends below the breast.
`
`usam ;
`
`H303 ;
`
`Q_
`
`A.
`
`Qkay_
`
`So —— and depending on the stage o;
`
`H305 ;
`
`pregnancy.
`
`So i: you —— :'m not sure if you've got
`
`H3&w ;
`
`children, but --
`
`11:30:29
`
`U30”
`
`1P%B4
`
`U30%
`
`H3&%
`
`U30”
`
`Q_
`
`A.
`
`: do _
`
`th y
`
`th y
`
`wh n
`
`th first—term
`
`pregnancy,
`
`there's usually, obviously,
`
`a smaller
`
`bump, and as it grows, it expands.
`
`Q_
`
`A.
`
`Uh_huh_
`
`So the maternity clothing will expand with
`
`CENTEXT LEGAL SERVICES
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`
`81
`
`DMC Exhibit 2018_081
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`N30“
`
`U30“
`
`U30“
`
`U30“
`
`U30%
`
`U3LW
`
`Ufikw
`
`Ufikm
`
`Ufitm
`
`the bump and —— hope‘u'ly.
`
`Some women like to pull
`
`them up.
`
`Some women like to roll them down.
`
`It
`
`depends on their own comfort level. This partf
`
`case, Layette, he had maternity pants that had
`
`tubular knit on the top tqat you could either have
`
`them rolled down or have them rolled up.
`
`Q.
`
`Okay. What about —— what about Rosanna?
`
`What kind of work were they in?
`
`A.
`
`Rosanna's had more o:
`
`from what
`
`H3t% ;
`
`recall, had more of panels in the front rather than
`
`Hfikm L
`
`the tubular knit.
`
`Hfikw ;
`
`Q.
`
`Okay.
`
`So Rosanna made maternity pants, as
`
`Hfikw L
`
`well?
`
`11:31:18
`
`:_
`
`A.
`
`Yes.
`
`Hfikm ;
`
`HSLH
`
`Ufikfl
`
`L
`
`.
`
`.
`
`And what did you mean by "panels in the
`
`They would be stretch —— stretch —— made
`
`1kfi24 '
`
`'
`
`tretch "abr’cs that could be inserted and sewn
`
`Ufitw ’
`
`‘n to the front of the garment that could expand
`
`Ufikfl
`
`U3LB
`
`1PN34
`
`nstfl
`
`n3Lm
`
`U31”
`
`with the garment --
`
`.
`
`.
`
`_
`
`Okay.
`
`Now, when you --
`
`—— expand with the pregnancy.
`
`sQrry_
`
`When you did consulting with Layette and
`
`CENTEXT LEGAL SERVICES
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`
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`
`DMC Exhibit 2018_082
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U3P@
`
`Ufikw
`
`Hflkw
`
`Hfikfl
`
`1Lfl54
`
`U3ZW
`
`Ufilm
`
`H3Z%
`
`Hfilw
`
`Rosanna in the early 2000s, was that —— was that
`
`business coasulting or also product design?
`
`A.
`
`Both —— no.
`
`it was product design —— well,
`
`most o
`
`it is product design on my part. My
`
`background is product design. And "
`
`‘ounded the E
`
`atter reali
`
`ing that most designers don't have the
`
`business skills,
`
`so we help them on all aspects,
`
`from product design to merchandising to costing to
`
`‘finding ‘unding and helping them grow the company.
`
`H329 ;
`
`Q.
`
`What product design ideas did you give
`
`U3ZW L
`
`to —— to Layette and Rosanna?
`
`U3ZW L
`
`A.
`
`Wow. That's over lO years ago,
`
`so it's
`
`H319 ;
`
`hard to tell yo; exactly what kind of advice
`
`Hfilfl
`
`;
`
`to them. But
`
`they probably —— what happens when
`
`H3ZM-;
`
`they join the 5% ,
`
`they get one hour free
`
`U3lW L
`
`consultation, and so they would come in with their
`
`Hfilw ;
`
`products and sit down. We would review it and talk
`
`Hfilfl
`
`11:32:35
`
`L
`
`:_
`
`U32”
`
`U31“
`
`11344
`
`U32“
`
`1kfl50
`
`U319
`
`about what needed —— what
`
`i would suggest that they
`
`should do.
`
`In both cases,
`
`they went on to be good
`
`friends,
`
`so we're still —— we're still
`
`triends.
`
`both of them went on to have their own children
`
`found that the ‘ashion industry is a little too
`
`for them at this stage in li- G.
`
`Q.
`
`Since the early —— those consultations
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`83
`
`DMC Exhibit 2018_083
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U3Z%
`
`Ufilfl
`
`Hfilfi
`
`H33W
`
`Ufiim
`
`U33%
`
`U33%
`
`H310
`
`U315
`
`in the early 2000s; correct?
`
`A.
`
`Q.
`
`Correct.
`
`Okay.
`
`Since that time, have you done any
`
`maternity consulting?
`
`A.
`
`There's another company that I work with,
`
`Emma 3.
`
`[phonetic], and she's been doing active
`
`sportswear. And she's now doing a maternity wear
`
`becaise it's —— it's so simple.
`
`::'s a no—brainer
`
`becaise you've got maternity —— "<e yoga pants with
`
`H339 ;
`
`the tubular top tiat you can pull
`
`ip and down.
`
`So
`
`1kB24Z_
`
`she found that people were using tqem anyway --
`
`H33% ;
`
`buying them when they were pregnant,
`
`so she's just
`
`ILB28 ;
`
`started manufacturing specifically for materni'
`
`ILB33 ;
`
`Q.
`
`<ay. And when did you do the consul"
`
`11:33:37
`
`I.
`
`with H
`
`U33”
`
`A.
`
`I'm still working with her.
`
`H33“ ;
`
`Q. Working with her now. Okay.
`
`U33“
`
`Hfiifi
`
`;
`
`A.
`
`Q.
`
`i'm trying to find her investors.
`
`Now,
`
`I know you worked with a company
`
`Ufilw
`
`called Mother --
`
`U33fl
`
`H31fl
`
`ILB54
`
`IEB54
`
`U31%
`
`. Mothercare.
`
`.
`
`.
`
`.
`
`.
`
`—— Mothercare UK?
`
`Correct.
`
`Okay. When —— when was that?
`
`That was soon after " graduated. And then
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`84
`
`DMC Exhibit 2018_084
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U3¢%
`
`1LMfi4
`
`H3¢W
`
`H3¢B
`
`U3¢B
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`U3¢M
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`U3¢W
`
`H3¢fl
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`1k%34Z_
`
`: went
`
`to work for a knitwear company, and then
`
`went
`
`to work for Mothercare in London. What year?
`
`Going back a bit.
`
`So I would say about
`
`'72,
`
`'73.
`
`They're sti" ——
`
`Q. We",
`
`"
`
`think --
`
`.
`
`—— in business,
`
`: think.
`
`Q.
`
`"
`
`think if we look in your —— your
`
`declaration at paragraph 4 --
`
`A.
`
`Q.
`
`Uh—huh.
`
`-— you say there,
`
`"My first job in the
`
`U3¢% '
`
`fashion industry,
`
`in around l97O for Mothercare
`
`11:34:39
`
`I-
`
`UK.
`
`.
`
`. "?
`
`H3¢% ;
`
`H3¢m ;
`
`A.
`
`Q.
`
`Correct.
`
`Okay.
`
`So does that help you define when
`
`H3¢M-;
`
`you worked for Mothercare UK?
`
`H3¢% ;
`
`H3¢% ;
`
`A.
`
`Q.
`
`Correct. Right.
`
`Okay. When did you work for Mothercare UK?
`
`H3¢@ ;
`
`A. Well, it was around l970.
`
`So i was
`
`U3¢fl
`
`’
`
`'
`
`terning for the knitwear company, and then
`
`U3¢%
`
`U3¢W
`
`H3¢%
`
`H3¢%
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`nsim
`
`Ufiiw
`
`‘fered this job at Mothercare.
`
`Q.
`
`A
`
`Q.
`
`A
`
`Q
`
`So this was your first job?
`
`Real
`
`job.
`
`And what did you do for Mothercare?
`
`Wesign=ng_
`
`What did you design?
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`85
`
`DMC Exhibit 2018_085
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`1k%04
`
`H3i%
`
`11:35:08
`
`U3i%
`
`U35“
`
`Ufiifl
`
`1k%24
`
`Ufiifi
`
`Ufiifl
`
`AJ Maternity wear.
`
`Q.
`
`A_
`
`Q.
`
`Did you design maternity pants?
`
`yes _
`
`Did you design maternity pants where the
`
`upper edge o:
`
`the belly panel on the maternity pants
`
`went
`
`to just below the breast area?
`
`Ad
`
`At that time,
`
`the style of
`
`thing was --
`
`they had what we call a higher rise on the pants.
`
`So i: you look at the rise o: pants or jeans today,
`
`H3i% ;
`
`they're around about 5 or 6 inches " —— 5 inches,
`
`Hfiiw ;
`
`id say. And a-
`
`that
`
`time,
`
`the rise on the pants,
`
`H358 ;
`
`typically, at
`
`tha- -ime was around about
`
`7
`
`inches.
`
`H3i% L
`
`So when you included a knit panel
`
`in the front, you
`
`Hfiifl
`
`;
`
`didn't really necessarily have to pull it up any
`
`1L%54 '
`
`H35? ;
`
`‘urther at that time because the actual pant was so
`I’
`Jhere was a —— it was a di ”erent
`
`much longer.
`
`Hfifiw ;
`
`style and a di”"erent fit.
`
`Hfifim ;
`
`Q. Where did the —— where did the top oi
`
`H36% ;
`
`pants end on a pregnant woman?
`
`U3&%
`
`U36”
`
`H368
`
`11:36:13
`
`Hfifim
`
`U3&W
`
`Al Well, we made them end above the abdomen,
`
`so they were —— it was a high rise. We call it a
`
`high rise --
`
`Uh—huh_
`
`A.
`
`—— and so that they would fit comjor
`
`over the abdomen. But, you know, o: course,
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`86
`
`DMC Exhibit 2018_086
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`N36”
`
`U363
`
`H365
`
`Ufififl
`
`U363
`
`U3@%
`
`U36”
`
`H36“
`
`U36“
`
`more pregnant you get,
`
`some women carry the
`
`pregnancy in di
`
`”erent ways.
`
`Some o:
`
`them carry
`
`high.
`
`Some of
`
`them carry low.
`
`So it's hard to say
`
`exactly where it would be.
`
`Some women carry it all
`
`the way around, and some women retain their
`
`' g'L1T‘€,°
`
`although,
`
`they're bigger at the front.
`
`So, you
`
`know, giving you a definition of where it hit, it's
`
`hard to tell you.
`
`Q.
`
`Okay.
`
`In the maternity pants that —— that
`
`U36“ L
`
`you were designing, did tie pregnant woman have to
`
`U36% L
`
`change pants as they got to di
`
`”erent stages o;
`
`Ufifiw L
`
`pregnancy?
`
`11:36:50
`
`Hfififl
`
`:_
`
`;
`
`U3&3 L
`
`A.
`
`Q.
`
`A.
`
`No.
`
`No.
`
`They wore the same pants?
`
`You would —— you know, six months —— up to
`
`H3&% l
`
`six months normally you can wear your normal —— your
`
`11136156
`
`L
`
`own pants.
`
`u3a% ;
`
`H36? ;
`
`Q_
`
`A.
`
`Qkay_
`
`And then after that, you would either leave
`
`U36”
`
`U3TW
`
`H3TW
`
`U3T%
`
`U3TW
`
`U3TW
`
`your fly open with a top over it or you would buy
`
`maternity pants.
`
`Q.
`
`Okay.
`
`So in those days, what women would
`
`do is they would only get the maternity pants for
`
`that last trimester or stage ol
`
`their --
`
`A.
`
`Stages; right. Well, depending on how they
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`87
`
`DMC Exhibit 2018_087
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`U3TB
`
`Ufilm
`
`H3?”
`
`U3?”
`
`U3?”
`
`1LW34
`
`U3T%
`
`11:37:40
`
`U3?“
`
`expand.
`
`Some women get bigger at three months.
`
`So
`
`it just depends on their own comfort level.
`
`Q.
`
`And since working at Mothercare UK —— how
`
`long were you at Mothercare UK?
`
`A.
`
`Probably about,
`
`I think,
`
`o
`
`”
`
`the whole --
`
`tarted teaching at the same time,
`
`so "
`
`think
`
`till
`
`‘reelancing ‘or them for about four years on
`
`aqd Q
`
`7_
`
`Q.
`
`How long were you working
`
`Hfiffl
`
`;
`
`Mothercare?
`
`H3TB l
`
`A.
`
`Two years,
`
`I think, approximately.
`
`H3T% ;
`
`hard to tell now.
`
`I
`
`tarted teaching in High
`
`Hfifw l
`
`Wycombe at that time.
`
`Hfifw ;
`
`Q.
`
`And what —— what was your position --
`
`Hfiffl
`
`11:37:55
`
`11:37:56
`
`Hfiffl
`
`;
`
`:_
`
`:_
`
`l
`
`position or positions at Mothercare?
`
`A_
`
`"Wes: gne1"_
`
`"Wes: gne1"_
`
`A,
`
`And patternmaker.
`
`Those days, you --
`
`H3&m ;
`
`you were a designer, you were expected to be abl
`
`U3&%
`
`U3&W
`
`H3&W
`
`U3&M
`
`U3&W
`
`U3&W
`
`do patterns, as well.
`
`These days, you don't as
`
`much. You're a designer, but you don't necessarily
`
`have to know the patternmaking skills,
`
`technical
`
`skills. Well, you still need the technical skills,
`
`but you're not expected to make the patterns, as
`
`you —— as we did.
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`88
`
`DMC Exhibit 2018_088
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`1L%19
`
`U3&N
`
`u3&n
`
`U3&B
`
`n3&m
`
`1F%24
`
`U3&%
`
`U3&N
`
`U3&fl
`
`_
`
`.
`
`.
`
`.
`
`..
`
`;
`
`L
`
`:
`
`.1
`
`Vern_
`
`-ern.
`
`Sorry. Not patent.
`
`It's my
`
`.
`
`I understood what you were saying.
`
`feeling the reporter might --
`
`.1 ”%R:
`
`Go ahead.
`
`” fl
`
`”
`
`1
`
`:
`
`Sorry.
`
`P—a—t—t—e—r—n.
`
`Sorry.
`
`.
`
`BY MR. POLLACK: And since working at
`
`H3&% ;
`
`thercare UK, have you worked for any other
`
`U3&@ L
`
`ternity companies?
`
`H3&B ;
`
`H3&% ;
`
`H3&fl
`
`11I38I54
`
`;
`
`I-
`
`H39W ;
`
`A.
`
`Q.
`
`Not as an employee, no.
`
`You say in paragraph —— well,
`
`let me ask
`
`you one other thing.
`
`I have your --
`
`MR. POLLACK:
`
`Can we have her CV?
`
`:'m going to mark as Harder Deposition
`
`H39“ ‘
`
`ixhibit TO the CV of Frances Harder.
`
`It's also
`
`H39W ;
`
`<nown as Exhibit
`
`lOL2 in the inter partes review
`
`H398 ;
`
`proceeding.
`
`U40W
`
`1k%04
`
`1P%04
`
`U40”
`
`U400
`
`U405
`
`(Patent Owner's Exhibit
`
`lO was marked
`
`for iden-ijicaLion and attached hereto.)
`
`Q.
`
`3Y MR. BOLLACK: And what
`
`I wanted to ask
`
`you is,
`
`I
`
`looked through your —— your CV, and
`
`don't see any mention of your working ‘or Mothercare
`
`or of any other work with the maternity industry.
`
`CENTEXT LEGAL SERVICES
`888.803.3443
`
`89
`
`DMC Exhibit 2018_089
`
`

`
`FRANCES HARDER
`
`April 24, 2014
`
`1P@30
`
`Ufififl
`
`Why is that?
`
`A4
`
`Probably because i‘
`
`" listed everything
`
`1k%fl4
`
`done, we would be —— created a book.
`
`So : didn't
`
`H403
`
`U40“
`
`ILMB4
`
`U40%
`
`UAQW
`
`U40%
`
`HAQQ ;
`
`HAQB ;
`
`I don't list all the jobs that I've had,
`
`just the
`
`most recent.
`
`Q.
`
`I see here you worked in l979 to l983 at
`
`Seattle Central Community College?
`
`.
`
`.
`
`_
`
`.
`
`Correct.
`
`Okay. That's not recent; correct?
`
`NO_
`
`Okay.
`
`So you have your --
`
`H%&% ;
`
`design degree from l968?
`
`H%&% ;
`
`HAQE ;
`
`A.
`
`O.
`
`Correct.
`
`Okay.
`
`So the CV does have ’n‘ormation
`
`HALW ;
`
`about your background going back to L968?
`
`Hfikw ;
`
`Hfikw ;
`
`A.
`
`Q.
`
`Correct.
`
`I wanted to take a look at your
`
`ILM24 L
`
`sel: published works.
`
`it's on page 3 through
`
`11:41:29
`
`:_
`
`page 4_
`
`11:

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