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` RICHARD DEVITO
` IN THE UNITED STATES
` PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` CASE NO: IPR2014-00477/IPR2014-00479
` PATENT NO.: 8,125,155 B2
`THE GILLETTE COMPANY, )
` )
` Petitioner, )
` )
`VS. )
` )
`ZOND, INC., )
` )
` Patent Owner. )
`-----------------------------------------
` CONTINUED VIDEO DEPOSITION OF
` RICHARD DEVITO
` (EXPERT WITNESS)
` BOSTON, MASSACHUSETTS
` WEDNESDAY, DECEMBER 17, 2014
` VOLUME II
`REPORTED BY:
`DENISE D. HARPER-FORDE
`Certified Shorthand Reporter (CSR)
`Certified Real-Time Reporter (CRR)
`Registered Professional Reporter (RPR)
`Notary Public (CT, MA, RI)
`CSR No. 000133
`JOB NO.: 88456
`
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`
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` RICHARD DEVITO
` IN THE UNITED STATES
` PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` CASE NO: IPR2014-00477/IPR2014-00479
` PATENT NO.: 8,125,155 B2
`THE GILLETTE COMPANY, )
` )
` Petitioner, )
` )
`VS. )
` )
`ZOND, INC., )
` )
` Patent Owner. )
`-----------------------------------------
` CONTINUED VIDEO DEPOSITION OF
` RICHARD DEVITO
` (EXPERT WITNESS)
` BOSTON, MASSACHUSETTS
` WEDNESDAY, DECEMBER 17, 2014
` VOLUME II
`REPORTED BY:
`DENISE D. HARPER-FORDE
`Certified Shorthand Reporter (CSR)
`Certified Real-Time Reporter (CRR)
`Registered Professional Reporter (RPR)
`Notary Public (CT, MA, RI)
`CSR No. 000133
`JOB NO.: 88456
`
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` RICHARD DEVITO
`
`Page 2
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` December 17, 2014
`
` Continued Video Deposition of RICHARD
`DEVITO, (Expert Witness), taken on behalf
`of the Patent Owner, at the law offices of
`WILMERHALE, 60 State Street, Boston,
`Massachusetts, at 9:50 A.M., Wednesday,
`December 17, 2014, before Denise D.
`Harper-Forde, Certified Shorthand Reporter,
`Registered Professional Reporter, Certified
`Real-Time Reporter, and Notary Public of
`the State of Massachusetts.
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` RICHARD DEVITO
` A P P E A R A N C E S
`
`ON BEHALF OF THE GILLETTE COMPANY:
`WILMERHALE
`BY: Cosmin Maier
`7 World Trade Center
`250 Greenwich Street
`New York, New York 10007
`
`ON BEHALF OF TAIWAN SEMICONDUCTOR
` MANUFACTURING COMPANY:
`DUANE MORRIS
`BY: Anthony Fitzpatrick
`100 High Street
`Boston, Massachusetts 02110
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` A P P E A R A N C E S (CONT'D)
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`Page 4
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`ON BEHALF OF ZOND, LLC:
`RADULESCU
`BY: Tigran Vardanian
`350 Fifth Avenue
`New York, New York 10118
`
`ALSO PRESENT: Gregory Huh
` (Via Teleconference)
`
` Larissa Park
` (Via Teleconference)
` David L. Cavanaugh
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` RICHARD DEVITO
` I N D E X
`
`WITNESS: RICHARD DEVITO
`
`EXAMINATION PAGE
` By Mr. Vardanian 6
`
` EXHIBITS
`NUMBER DESCRIPTION PAGE
`
`Exhibit 1011-A -- (Previously marked) 21
`Exhibit 1001-A -- (Previously marked) 27
`Exhibit 1003-A -- (Previously marked) 32
`Exhibit 1012 -- (Previously marked) 57
`Exhibit 1008-A -- (Previously marked) 75
`Exhibit 1014-A -- (Previously marked) 80
`Exhibit 1002-A -- (Previously marked) 143
`Exhibit 1018 -- (Previously marked) 156
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` RICHARD DEVITO
` * * * * * *
` BOSTON, MASSACHUSETTS
` Wednesday, December 17, 2014
` 9:50 p.m.
` * * * * * *
` VIDEOGRAPHER: This is the start of
`day 2, tape 1, of the continuing videotaped
`deposition of Richard DeVito.
` This deposition is being held at 60
`State Street, Boston, Massachusetts, on
`December 17th, 2014, at approximately 9:50
`AM.
` My name is LeeAnn. I am the legal
`video specialist from TSG Reporting, Inc.,
`headquartered at 747 3rd Avenue, New York,
`New York. The court reporter is Denise
`Harper-Forde in association with TSG
`Reporting.
` We would now continue the
`deposition.
` * * * * * *
` DIRECT EXAMINATION (CONT'D)
` (BY MR. VARDANIAN):
` Q. Mr. DeVito, good morning.
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` A. Good morning.
` Q. Welcome back.
` A. Thank you.
` Q. You realize you are still under
`oath?
` A. I do.
` MR. VARDANIAN: So just for the
`record, we used some exhibits during the
`first day of your deposition and we are
`having trouble locating them. They were
`left in Wilmer Hale's offices after the
`first day. So we are going to look for
`them. Wilmer Hale will look for them as
`well.
` I introduced some exhibits during
`the first day. I will reintroduce them,
`and we will mark them with the A, B, C, and
`we will try to deal with it that way.
` So I just wanted to make the record
`clear that there is going to be a duplicate
`version of some of the exhibits that we
`actually used during the first day.
` (BY MR. VARDANIAN):
` Q. Let me ask you: In your
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` RICHARD DEVITO
`declaration you stated that you have had no
`contact with the named inventor of the 775
`Patent. Do you agree with that
`statement?
` A. I never met him. I have seen him
`but I never met him.
` Q. Where have you seen him?
` A. So I believe -- I can't narrow down
`the date, but it's probably going on 10 to
`12 years ago I worked at a company called
`Nexx Systems, and we were, quote/unquote,
`squatting in the building owned by a
`different company.
` And I believe he stopped in there
`once to demonstrate a product to one of the
`people at Nexx Systems. This is -- I think
`it was in Wilmington. It was at a company
`called MKS.
` We were squatting -- not paying
`rent and squatting in there, and I think he
`had a relationship with the owner of Nexx
`or MKS or something, but I think he stopped
`by to demonstrate a product.
` I don't know all details. I wasn't
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` RICHARD DEVITO
`involved, but I believe someone mentioned
`to me that that guy is the inventor of this
`Patent, Roman.
` Q. You were one of the people who he
`was demonstrating the product to?
` A. It wasn't demonstrated to me, no.
` Q. So you state in the declaration
`that you have had no contact with the named
`inventor of the 755 Patent. Why was it
`important to make that statement in your
`declaration, in your opinion?
` MR. MAIER: Objection.
` THE WITNESS: I supposed it was
`because it would be a conflict of
`interest.
` (BY MR. VARDANIAN):
` Q. Have had any contact with the
`company owned by -- strike that.
` Have you had any contact with the
`inventor's company?
` A. So not directly. All I can tell
`you is that the local rep, so the way these
`companies work is they have reps that go
`out to the area to try to sell their
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`product.
` When I was at Northeastern, the
`local rep had approached me to try to get
`one of their supplies on loan to try out at
`the university setting, but we didn't have
`any application for that power supply. So
`I don't know.
` This was maybe five to seven years
`ago possibly. Maybe a little less, I can't
`recall. But we did speak on several
`occasions. They were trying to get the
`power supply at the university to use in
`sputtering.
` MR. VARDANIAN: Before I go to the
`next question, if we could have people who
`are on the phone actually identify
`themselves, I just heard that somebody else
`joined.
` MR. CAVANAUGH: I believe that was
`Mr. Huh redialing in, and he has indicated
`to me by e-mail that he's having a problem
`hearing. But I do believe that's Mr. Huh.
` MR. VARDANIAN: They have an
`ability to speak up, right?
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` MR. CAVANAUGH: We'll check on it
`at the break.
` MR. VARDANIAN: That's fine.
` But your understanding is that the
`only people that are on the phone right now
`are Mr. Huh and Ms. Park?
` (BY MR. VARDANIAN):
` Q. What is the name of the rep that
`you mentioned?
` MR. MAIER: Objection, relevance.
` THE WITNESS: His name is Andrew
`Coulter, C-O-U-L-T-E-R.
` (BY MR. VARDANIAN):
` Q. And he's the rep of what company?
` A. He's a one-person shop. I'm just
`trying to think -- I don't know the actual
`name of his company. If you Google Andrew
`Coulter, I believe something will come
`up.
` Q. But he's the rep for ZPulser ZOND,
`right?
` MR. MAIER: Objection, foundation.
`Objection, relevance.
` THE WITNESS: Yes. At the time
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`that he spoke to me, whatever that time
`period was, a couple of years ago, he
`represented himself as such and I believe
`was listed on his line card.
` Reps have line cards on the
`different equipment manufacturers they
`represent.
` (BY MR. VARDANIAN):
` Q. So you had contact with ZPulser
`ZOND; correct?
` MR. MAIER: Objection, relevance.
` THE WITNESS: Nobody directly at
`the company, so he doesn't work for them.
`He's an independent rep. I believe he gets
`paid on commission.
` (BY MR. VARDANIAN):
` Q. So it's your testimony under oath
`today that you haven't met anybody who
`actually works either for ZOND or ZPulser;
`is that your statement?
` MR. MAIER: Objection, relevance.
` THE WITNESS: To the best of my
`recollection, no -- yes, I have not met
`anybody that works directly for ZOND.
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` (BY MR. VARDANIAN):
` Q. Have you ever met Bassam Abraham?
` A. To the best of my recollection, no.
`I could have. I know the name is familiar
`but I don't remember meeting him.
` Q. You said the name is familiar. How
`is the name familiar?
` A. He checked me out on LinkedIn a
`couple of times.
` Q. But you never met him?
` A. To the best of my recollection,
`no.
` Q. Have you ever, in your capacity at
`Northeastern, considered buying a power
`supply from ZOND or ZPulser?
` MR. MAIER: Objection, relevance.
` THE WITNESS: So, when I originally
`started talking to Andy, certainly we were
`in discussions to try to do that. But over
`the course of several months when I looked
`into the technology -- not the technology,
`I mean looked into the size of the supplies
`were quite large.
` I don't know if you're familiar.
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`They are the size of, like, a dorm
`refrigerator. And so we just did not have
`the room in the fab that I worked to even
`demonstrate, let alone buying one. You
`have to understand at the university, we
`get a lot things that are sort of donated
`or at cost.
` We don't have the capability to
`buy -- I don't know how much the supplies
`cost. We never talked about that. We
`originally talked about doing it as a
`loaner.
` And I suspect they just wanted to
`have a place to do some work, maybe. I
`don't know. But we just couldn't work out
`the detail. It was just so large.
` (BY MR. VARDANIAN):
` Q. Why were you interested in
`acquiring a zPulser power supply?
` MR. MAIER: Objection, form and
`relevance.
` THE WITNESS: Well, at the fab that
`I work, one of the things -- one of our
`missions is to look at all different
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`technologies and see how they help or
`detract from people's processes.
` (BY MR. VARDANIAN):
` Q. Did you do any kind of an
`assessment of the technology that was used
`for the power supplies?
` MR. MAIER: Same objections.
` (BY MR. VARDANIAN):
` Q. Did you do any kind of an
`assessment of the technology that was used
`for the supplies by ZPulser or ZOND?
` MR. MAIER: Objection, form,
`relevance.
` THE WITNESS: So when I had talked
`to Andy, he gave me a brief overview of the
`technology. And then I looked on the
`Website and I read a couple of things at
`the time that they had there.
` At the time they didn't have a lot.
`They had -- I believe it was like a power
`point presentation or something like that.
`But I could glean from that -- I did look
`at the technology.
` (BY MR. VARDANIAN):
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` Q. What was your impression of the
`technology at the time?
` MR. MAIER: Objection, form.
`Objection, relevance.
` THE WITNESS: What do you mean, was
`it good, was it sound? I mean --
` (BY MR. VARDANIAN):
` Q. Any of those, but also whatever
`other impressions you had of the technology
`at the time.
` MR. MAIER: Objection to form,
`relevance.
` THE WITNESS: So I understand that
`the technology was about ionization of the
`sputter particles and the neutral
`particles. And certainly it would have
`been nice to have some of that technology.
` But the ZOND technology, you know,
`just -- you know, we had other supplies he
`were looking at that could give us some of
`the aspects of ZOND's in terms of the
`ionization, but not some of the other
`aspects which ZOND has the claims of a
`higher ionization than the existing
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`technology at the time.
` (BY MR. VARDANIAN):
` Q. And the time frame, if you could
`help me, of when this was happening.
` MR. MAIER: Same objections.
` THE WITNESS: Just let me try to
`recall. I have to give you a range. That
`is the best I can do.
` (BY MR. VARDANIAN):
` Q. That is fine if that is the best
`you can do.
` A. Maybe five -- approximately five,
`six, seven years ago, somewhere in that
`range.
` Q. So you mentioned that you had other
`power supplies at the time --
` A. We were looking at them. Sorry.
` Q. Let me just finish the question.
` You mentioned that you had other
`power supplies but some of the aspects of
`what ZOND power supplies were offering was
`not something that you had at the time; is
`that correct?
` MR. MAIER: Objection to form,
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`objection to relevance.
` THE WITNESS: Would you repeat it,
`please.
` (BY MR. VARDANIAN):
` Q. What were those aspects that the
`other power supplies did not have at the
`time that ZOND power supplies did?
` MR. MAIER: Same objections.
` THE WITNESS: The other power
`supplies we're looking at did ionization,
`just not at the level that ZOND had claims
`on.
` You could ionize the metal
`particles but not the high level that ZOND
`had claims on. It was an older supply so
`we would get it for almost free.
` (BY MR. VARDANIAN):
` Q. What is that high level that you're
`referring to?
` MR. MAIER: Same objections, form,
`relevance.
` THE WITNESS: I don't recall the
`details from the literature that I read at
`the time. But, you know, compared to what
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` RICHARD DEVITO
`I was looking at, what I was looking at,
`they were getting -- the supplies were
`getting five, ten percent ionization, and
`ZOND had claims that were higher than that,
`so much higher that they said. I don't
`know the exact number.
` (BY MR. VARDANIAN):
` Q. You mentioned a lecture you read at
`the time. What is this lecture that you're
`referring to?
` MR. MAIER: Objection to relevance.
`Objection to form.
` THE WITNESS: So I believe at the
`time there was some power point
`presentation on the ZOND Website that
`described their technology.
` (BY MR. VARDANIAN):
` Q. So you went on ZOND's Website?
` MR. MAIER: Objection to form,
`objection to relevance.
` THE WITNESS: I believe I said
`that, yes.
` (BY MR. VARDANIAN):
` Q. And You read the power point that
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` RICHARD DEVITO
`was available from ZOND's Website?
` MR. MAIER: Same objections.
` THE WITNESS: Yes.
` MR. VARDANIAN: So who joined?
` MR. MAIER: I think the folks on
`the phone may not be able to hear us, based
`on what Mr. Huh's reported to us.
` (BY MR. VARDANIAN):
` Q. So it would be fair to say that you
`had contact with ZOND in the past;
`correct?
` MR. MAIER: Objection to form.
`Objection, relevance.
` THE WITNESS: I thought you had
`asked me if I had contact with anyone, any
`person at ZOND. I certainly knew about
`ZOND and the company by way of Andrew.
` So in terms of personal contact
`with people at there, the question would
`be, no, I did not, to my recollection.
` MR. VARDANIAN: Let me reintroduce
`what has previously been marked as an
`Exhibit, and would introduce this exhibit
`from the first day of your deposition as
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` RICHARD DEVITO
`Exhibit 1011. Let's mark it as Exhibit
`1011-A.
` (Whereupon, Exhibit 1011-A, was
` marked for identification)
` (BY MR. VARDANIAN):
` Q. So at the end of day one of the
`deposition, we were talking about your
`statements and opinions in the declaration
`regarding the combination of Wang and
`Kudryavtsev.
` Do you recall that?
` A. Can you refer to which claim we are
`talking about?
` Q. Sure. I can actually refer you to
`-- let's go to page 73, paragraph 157. So
`before we actually delve into this, if you
`could help me understand this.
` The experiment that is described in
`the Kudryavtsev reference is not using a
`catho-target; right, is it?
` A. So you mean a catho-target means
`something that is going to sputter and
`create a film?
` Q. Correct.
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` RICHARD DEVITO
` A. In that sense, no. He does have a
`cathode, but not a target cathode.
` Q. Right. So there is nothing to --
`there is no cathode for sputtering
`purposes; correct, in the device that he
`was using?
` A. Correct. Just for plasma support,
`yes.
` Q. There was also no magnetic field;
`right?
` A. Correct.
` Q. So you see the first sentence in
`paragraph 157?
` A. I do.
` Q. You state in your declaration that
`the combination of Wang and Kudryavtsev
`teaches generating excited atoms in the
`weakly ionized plasma. Do you see that?
` A. I do.
` Q. And it seems that at least one of
`the reasons why you are saying this is
`later in the paragraph, the sentence that
`starts with "Moreover, it would have been
`obvious to combine Wang and Kudryavtsev;"
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` RICHARD DEVITO
`is that fair?
` A. Let me just quickly read that.
` I'm sorry. Repeat the question.
` Q. What I was asking was whether one
`of the reasons why you believe that the
`combination of Wang and Kudryavtsev teaches
`generating excited atoms in the weakly
`ionized plasma is this statement that you
`provide later in the paragraph which starts
`with "Moreover, it would have been
`obvious." Do you see that?
` MR. MAIER: Objection to form.
` THE WITNESS: And that is certainly
`one of the effects. Kudryavtsev, like
`Wang, has a pre-ionized plasma, and they
`both apply electric field very quickly to
`that plasma and they get the multi-stage
`growth that Kudryavtsev expects which leads
`to the rapid ionization.
` (BY MR. VARDANIAN):
` Q. So, let's just break that up
`quickly.
` So it's your view that Wang teaches
`quick application of electric field that
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` RICHARD DEVITO
`creates the plasma?
` A. Wang in view of Mozgrin -- I'm
`sorry, Wang in view of Kudryavtsev, yes.
` Q. Just Wang on its own. So, again,
`let's step back.
` So Kudryavtsev, in your view, in
`your opinion, teaches application -- sudden
`application of an electric field on weakly
`ionized plasma?
` A. I'm sorry. Did you refer to Wang
`or Kudryavtsev?
` Q. Kudryavtsev. Let's take them one
`at a time.
` In your opinion, Kudryavtsev
`teaches a sudden application of an electric
`field to weakly ionized plasma; that is
`what you are saying?
` A. Correct.
` Q. You're also saying that Wang
`teaches the same thing; correct?
` A. Correct.
` Q. So that's the reason why you
`believe that they can be combined together;
`right?
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` RICHARD DEVITO
` MR. MAIER: Object to form.
` THE WITNESS: Let me just review
`the claim language, just the claim it's
`referring to, and I have to look back to
`the previous section like I did last time,
`where the claim is actually stated.
` (BY MR. VARDANIAN):
` Q. So before we go to the claim, and I
`will give you the patent in a second, but
`you have an opinion with respect to that
`these two references can be combined for
`obviousness purposes; right?
` A. Correct.
` Q. And it's stated here in paragraph
`157 of page 73 of your declaration;
`right?
` A. Yes.
` Q. I'm just trying to understand why
`you believe these two references can be
`combined for obviousness purposes. So you
`mentioned that both of them suddenly apply
`an electric field to weakly ionized plasma?
` MR. MAIER: Objection to form.
` THE WITNESS: Yes.
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` RICHARD DEVITO
` (BY MR. VARDANIAN):
` Q. My question to you is: Do you
`believe that is the reason why they can be
`combined for the obviousness purposes?
` A. I have to see it in relationship to
`the claim that I am referring to, because
`there are claims of a rapid excitement of
`the atoms, so I need to know what 57 is
`referring to in the claim language before I
`can give you a proper answer.
` Q. So without the claim language,
`you're saying that you can't tell me
`whether your opinion concerning the
`combination of Wang and Kudryavtsev stated
`in paragraph 157 of your declaration is
`accurate or not?
` MR. MAIER: Objection to form.
` THE WITNESS: It is accurate. But
`there are different combinations of Wang
`and Kudryavtsev that were referred to in a
`different claim. I just want to make sure
`I have that particular combination right
`for that claim.
` MR. VARDANIAN: So let me
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` RICHARD DEVITO
`reintroduce what has been previously marked
`as Exhibit 1001. And we are going to mark
`it as 1001-A, because the previous version
`that we were using on day one was actually
`marked by you.
` If you remember, we had a
`discussion? Actually, strike that. I
`don't think that was about this reference.
` So I am still going to reintroduce
`it as 1001-A.
` (Whereupon, Exhibit 1001-A, was
` marked for identification)
` THE WITNESS: I can also read a
`little bit before also as well; is that
`okay? Because I believe these are all
`linked, so I just want to make sure I have
`everything in my head.
` (BY MR. VARDANIAN):
` Q. As you are doing that -- by all
`means, you can take your time, but I just
`want to make sure that the question that is
`pending for you and the question that I am
`asking you to respond to is whether it's
`your opinion that the Wang reference and
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` RICHARD DEVITO
`Kudryavtsev reference can be combined for
`obviousness purposes because both
`references disclose application of electric
`fields, sudden application of electric
`field to weakly ionized plasma.
` Do you understand my question?
` MR. MAIER: Objection to form.
` THE WITNESS: I was wondering if
`you could point me out where the E claim
`is. I can look for it in here, but you may
`not want me to look for it in there.
` (BY MR. VARDANIAN):
` Q. Where the limitation E of claim one
`is?
` A. Right.
` Q. So, if we go to claim one, which
`starts in column 21 of the 775 patent,
`which is Exhibit 1001 and 1001-A.
` A. We do refer to it in one of the
`previous grounds, but it's unclear where A
`starts.
` Q. Well, let's get back because it's a
`little bit odd for me to tell you what is
`in your declaration.
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` RICHARD DEVITO
` So limitation E of claim one and
`limitation E of claim 15 is how you
`identify limitations in your declaration;
`correct?
` A. Correct.
` Q. So let me turn that back to you.
` What do you believe limitation E of
`claim one is?
` A. I have to refer back to the
`previous -- I know it's in one of other
`grounds. Because of page restrictions, we
`couldn't repeat all of the limitations so
`I'm going to have to refer back to that,
`sorry.
` Q. If I were to guess, and maybe we
`can stipulate with counsel, but to speed
`this up, I believe it's -- in claim one
`it's the limitation that starts with the
`power supply dec.
` MR. MAIER: And if you would like
`me to help, I think what he is saying is he
`assigned letters to each claim limitation
`earlier.
` MR. VARDANIAN: I appreciate that,
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` RICHARD DEVITO
`and I understand. I think we can try to
`speed this up. To be perfectly honest, I
`would be guessing. My guess would be it's
`the limitation that starts with the power
`supply deck in claim one because it's
`sequentially fifth, which would be the -- E
`is the fifth letter.
` (BY MR. VARDANIAN):
` Q. And with respect to claim 15, where
`limitation C is referred to, I think it's
`the limitation that starts with applying an
`electric field across the weakly ionized --
` MR. MAIER: Sorry, I missed that.
` (BY MR. VARDANIAN):
` Q. So limitation C is in the same
`subsection of claim 15?
` MR. MAIER: I believe that is
`right.
` (BY MR. VARDANIAN):
` Q. So let's proceed under that
`assumption that, for claim 1, I think that
`we have confirmed this, for claim 1, this
`limitation E is the limitation that starts
`with the power supply dec; and for claim
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` RICHARD DEVITO
`15, it's the limitation that starts with
`applying the electric field across the
`weakly ionized plasma.
` A. So back to your question. I don't
`want -- I have to ask you to just repeat it
`one more time and I can answer it.
` Q. Sure.
` My question is: Is it your opinion
`that the Wang reference and Kudryavtsev
`reference can be combined for obviousness
`purposes because both references disclose
`application of -- sudden application of
`electric field to weakly ionized plasma?
` A. Yes.
` Q. So let's look at this quote on page
`73 where you quote Kudryavtsev reference --
`let's just make sure that you agree that
`this is a quote from Kudryavtsev.
` Do you see on the line -- second
`line from the bottom a cite to Kudryavtsev?
` A. At the bottom, yes, Kudryavtsev at
`34 right column, paragraph 4?
` Q. Right. So you agree that the
`passage that is quoted preceding that
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` RICHARD DEVITO
`reference to Kudryavtsev is a quote from
`Kudryavtsev's reference; right?
` MR. MAIER: Object to form.
` THE WITNESS: I would hope it is.
`I would have to look at the actual
`Kudryavtsev reference.
` (BY MR. VARDANIAN):
` Q. So let me reintroduce what has been
`previously marked as Exhibit 1003. We will
`mark it as Exhibit 1003-A.
` (Whereupon, Exhibit 1003-A, was
` marked for identification)
` (BY MR. VARDANIAN):
` Q. I can help you. If you go all the
`way to the very last sentence of the
`substantive portion of the reference.
` A. Page 34?
` Q. Page 34, I believe it's the last
`sentence that starts with "since."
` A. Okay. "Since the effects studied
`in this work are characteristic of
`ionization, whenever a field is suddenly
`applied to a weakly ionized gas," et
`cetera, et cetera. So in the bottom of
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`Page 3
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