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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`-------------------------------------------------------------
`THE GILLETTE COMPANY, et al.,
` Petitioners,
` Patent No. 6,896,775
` -vs- IPR 2014-00578
` IPR 2014-00604
`ZOND, LLC, IPR 2014-01482
` IPR 2014-01494
` Patent Owner.
`-------------------------------------------------------------
`
` 7701 WEST BRANCH HIGHWAY
` LEWISBURG, PENNSYLVANIA
` April 3, 2015 - 11:30 A.M.
`
` VIDEOTAPED DEPOSITION of JOHN BRAVMAN, Ph.D., before S.
`Arielle Santos, Registered Professional Reporter, Certified
`Shorthand Reporter, Certified LiveNote Reporter and Notary
`Public.
`
`JOB NO. 92169
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` APPEARANCES:
`COUNSEL FOR PETITIONER:
`BY - COSMIN MAIER, ESQ.
`BY - YUNG-HOON HA, Ph.D.
`WILMERHALE
`7 World Trade Center
`250 Greenwich Street
`New York, New York 10007
`
`COUNSEL FOR PATENT OWNER:
`BY - TAREK FAHMI, ESQ.
`ASCENDA LAW GROUP
`333 West San Carlos Street
`San Jose, California 95110
`
`ALSO PRESENT:
` LARRY MOSKOWITZ, Legal Videographer
`
`TSG Reporting - Worldwide 877-702-9580
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`IPR2014-00578 Zond Ex. 2012
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`Page 3
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` E X A M I N A T I O N S
`
`Witness Page
`JOHN BRAVMAN, Ph.D. 5
` BY MR. FAHMI 5
` BY MR. MAIER 55
` BY MR. FAHMI 66
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` JOHN BRAVMAN, Ph.D.
` THE VIDEOGRAPHER: Good morning.
`We are now on the record. This is the
`start of Tape Label Number 1 of the
`videotaped deposition of John C.
`Bravman, PhD, in the matter of
`Gillette Company versus Zond, Inc.
` This deposition is being held at
`the Best Western, 7701 West Branch
`Highway, Lewisburg, Pennsylvania, on
`April 3, 2015, at approximately
`11:00 a.m.
` My name is Larry Moskowitz, and
`I am the legal video specialist.
` Will counsel please introduce
`themselves for the record.
` MR. FAHMI: Tarek Fahmi on
`behalf of the patent owner Zond.
` MR. MAIER: Cosmin Maier of
`WilmerHale on behalf of Petitioner The
`Gillette Company, and with me is my
`colleague Sam Ha.
` THE VIDEOGRAPHER: Will the
`reporter please administer the oath.
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` JOHN BRAVMAN, Ph.D.
`JOHN C. BRAVMAN, PhD, having been duly
`sworn, testifies as follows:
`
` EXAMINATION
`BY MR. FAHMI:
` Q Can you state your name for the
`record, please.
` A John Cole Bravman.
` Q Dr. Bravman, good morning. My
`name is Tarek Fahmi, and as I just
`mentioned, I am representing the patent
`owner Zond in this proceeding.
` And we are here today for your
`deposition in connection with inter partes
`reviews that have been filed by The
`Gillette Company and others concerning US
`Patent 6,896,775.
` Do you understand that?
` A Yes, I do.
` Q Have you ever been deposed before,
`sir?
` A Yes, I think this is my 31st
`deposition.
` Q I will just give you a couple of
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` JOHN BRAVMAN, Ph.D.
`quick ground rules since I am sure you are
`familiar with them.
` As you are doing now, please
`continue to give audible answers to the
`questions that I am going to ask you today.
`It helps the court reporter keep an
`accurate record, and she has difficulty
`taking down things like nods of the head
`and "uh-huh" and "hm-hm" and even though
`it's being videotaped, we do want the
`transcript itself to be clear.
` Is that all right?
` A Yes.
` Q And if I ask any questions today
`that you didn't hear or didn't understand
`or simply want clarification, just let me
`know and I will be happy to repeat them or
`rephrase them. All right?
` A Yes.
` Q And finally, as you are doing now,
`I'd ask that you try to wait until I finish
`asking a question before you give your
`answer and I will try to extend the same
`courtesy and wait until you have completed
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` JOHN BRAVMAN, Ph.D.
`your answer before I ask another question.
`Is that all right?
` A Yes.
` Q And I am going to assume that if
`you answer a question that you're answering
`the question that I have asked unless you
`have asked for clarification.
` Is that okay?
` A Yes.
` Q Is there any reason why you
`couldn't give your best testimony in this
`proceeding today?
` A No.
` Q Are you taking any medications or
`anything that might affect your memory?
` A No.
` Q Any other reason you couldn't give
`your best testimony?
` A No.
` Q Do you have any questions before
`we begin?
` A No.
` Q Dr. Bravman, you provided a
`declaration on behalf of the petitioners in
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` JOHN BRAVMAN, Ph.D.
`this matter.
` Is that right?
` A Yes.
` Q I have handed you a copy of what's
`been previously marked as Gillette's
`Exhibit 1031.
` Do you recognize this exhibit?
` A (Reviewing.)
` Yes.
` Q Do you recognize it as a copy of
`the declaration that you provided in this
`proceeding?
` A Yes.
` Q When were you retained by the
`petitioners in this matter?
` A I believe several months ago.
` Q Can you be more specific?
` A I didn't check the dates, but it
`was early 2015.
` Q In January?
` A I think it was in January.
` Q As part of that retention and as
`part of the preparation of your
`declaration, you reviewed certain
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` JOHN BRAVMAN, Ph.D.
`materials; is that right?
` A Yes.
` Q One of those materials was the
`'775 patent of Chistyakov; is that correct?
` A Yes.
` Q I have handed you a copy of what's
`been previously marked as Gillette's
`Exhibit 1001.
` Do you recognize it as a copy of
`the '775 patent?
` A Yes.
` Q When was the last time you had a
`chance to review the '775 patent?
` A Last night.
` Q As you set about preparing your
`declaration in this matter, how did you
`proceed?
` A I read the documents that were
`pertinent and available to me, including
`the patent -- the patents and other
`documents that I cited in my declaration,
`typically, many times.
` Q Do you recall what you read first?
` A This patent that you just handed
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` JOHN BRAVMAN, Ph.D.
`me, Gillette 1001.
` Q '775 patent?
` A Yes.
` Q So before you consulted any other
`materials, you read the '775 patent; is
`that right?
` A Yes.
` Q So you had the contents of the
`'775 patent in your mind as you reviewed
`the other materials in this proceeding in
`connection with the preparation of your
`declaration; is that correct?
` A I had not memorized it, but yes,
`the contents were in mind.
` Q As part of that review, did you
`read the claims of the '775 patent?
` A Yes, I did.
` Q So is it fair to say that as you
`reviewed other materials in connection with
`the preparation of your declaration, you
`had the subject matter of the claims of the
`'775 patent in mind?
` A Yes.
` Q I would like to turn to paragraph
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` JOHN BRAVMAN, Ph.D.
`7 of your declaration. It's on page 4.
` A Yes.
` Q You indicate that in the course of
`your various research, that you and your
`research groups have made use of plasma
`deposition equipment; is that right?
` A Yes.
` Q Have you ever designed plasma
`deposition equipment?
` A No.
` Q If you would please turn to
`paragraph 13 of the declaration.
` A I have that.
` Q In paragraph 13, you express the
`opinion that a person of ordinary skill in
`the art for the '775 patent would have
`found that patent invalid; is that right?
` A Yes.
` Q Does that mean that such a person
`of ordinary skill in the art needs legal
`training to reach that conclusion?
` MR. MAIER: Object to form.
` THE WITNESS: My understanding
` is that, ultimately, invalidity is a
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` JOHN BRAVMAN, Ph.D.
` matter of law and I am not an attorney
` but from a scientific or technical
` viewpoint and with the understanding
` that I have been provided many times,
` I reached that conclusion.
`BY MR. FAHMI:
` Q So you feel competent in patent
`law in order to reach a conclusion of
`validity or not; is that right?
` A Again, from a technical viewpoint,
`yes, but I understand ultimately it's a
`matter of law and for a judge or jury or
`panel to decide.
` Q Do you consider yourself competent
`to render an opinion about patent validity?
` A Yes.
` Q What is that competency based on?
` A My technical work based -- 30-plus
`years of technical work and the many IP
`cases that I have been involved with and
`the instruction I have received, although,
`again, as it says, I am not an attorney.
` Q Other than instructions you may
`have received from counsel, have you ever
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`read any patent opinions of any court?
` A Yes.
` Q What are those opinions?
` A I can't recall. I know that I
`have been doing this kind of work for about
`15 years and I know in other cases, not in
`this case, I have read opinions of the
`court.
` Q Are you familiar with any Supreme
`Court opinions in the patent law?
` A Not as I sit here, no.
` Q Are you familiar with Graham v.
`John Deere?
` MR. MAIER: Object to form.
` THE WITNESS: No.
`BY MR. FAHMI:
` Q Is it fair to say that any
`opinions you would express regarding
`validity would be based upon instructions
`concerning the legal subject matter you
`would have received from counsel?
` A Plus my own technical knowledge
`were it a technical matter.
` Q But you told me that a conclusion
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`of validity is a matter of law; is that
`right?
` A Ultimately, yes, that's my
`understanding.
` Q So in order to reach that
`determination, you would have to apply some
`legal analysis, right?
` MR. MAIER: Objection to form.
` THE WITNESS: Someone would. I
` am offering a technical opinion and
` then, as best as I understand it, from
` a technical viewpoint, it meets the
` criteria that I have instructed as
` consistent with finding of validity.
`BY MR. FAHMI:
` Q So what technical requirements
`must exist in order to reach a finding of
`invalidity?
` A By technical requirements, I meant
`the science or engineering of the matter at
`hand, not the technicalities of the law.
` Q Other than the information you
`indicate has been provided in the
`declaration concerning the legal principles
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`applicable to this case, do you have any
`training in patent law?
` A No, I have no formal training in
`patent law.
` Q So in order to reach a conclusion
`of validity or not, you would apply
`instruction that you receive from counsel
`regarding the legal test for validity; is
`that right?
` A Built upon the scientific or
`engineering understanding that I formed,
`yes.
` Q If you would turn to paragraph 26,
`please.
` A (Reviewing.)
` Yes.
` Q In paragraph 26, you make
`reference to the prior art.
` Do you see that?
` A (Reviewing.)
` Yes.
` Q What prior art are you referring
`to?
` A The prior art that I articulate
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` JOHN BRAVMAN, Ph.D.
`throughout the length of my declaration.
`The prior art as -- here, generically, as a
`collective and in various places, and in
`the materials considered, I list what those
`pieces of prior art are.
` Q So you weren't suggesting that it
`was the entirety of the known literature in
`paragraph 26.
` You were simply referring to the
`references that you cite elsewhere in the
`declaration; is that right?
` A Those references read by a person
`of ordinary skill in the art and the
`background knowledge and experiences that
`that hypothetical person had.
` Q In paragraph 20 you provide an
`opinion about what the education --
`educational and professional background for
`such a person of ordinary skill in the art
`would be; is that right?
` A Yes.
` Q How did you derive that opinion?
` A In many such matters, I have used
`a similar description. It's based on
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` JOHN BRAVMAN, Ph.D.
`training large numbers of students at the
`bachelor's, master's and PhD level, working
`with people in industry for 25 years in a
`collaborative fashion, understanding who
`did what, and my sense of what someone with
`a bachelor of science degree in these or
`related fields would know. And then the
`extra knowledge that was gained would be
`gained in actually working in the field for
`a few years after the formal training came
`to an end.
` Q As part of your analysis in
`connection with the preparation of your
`declaration, I think you indicated you read
`the declaration provided by Dr. Hartsough;
`is that right?
` A Yes.
` Q Do you know whether or not your
`opinion concerning the level of ordinary
`skill in the art agrees with that expressed
`by Dr. Hartsough?
` A As I recall, he had a slightly
`different description, but I can't remember
`it as I sit here at this moment.
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` JOHN BRAVMAN, Ph.D.
` Q I don't think you disagreed with
`Dr. Hartsough's opinion considering the
`level of ordinary skill, did you?
` A I certainly did not write that
`here.
` Q I have handed you what has been
`previously marked as Gillette's
`Exhibit 1008.
` Do you recognize this exhibit?
` A Yes.
` Q Do you recognize it as a copy of
`the Wang patent, US Patent 6,413,382?
` A Yes.
` Q If I refer to it as "Wang," will
`you understand that I am referring to this
`Exhibit 1008?
` A Certainly.
` Q The Wang patent was one of the
`references that you considered in
`connection with the preparation of your
`declaration; is that right?
` A Yes.
` Q Would you agree that Wang
`describes applying DC power pulses to a
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`TSG Reporting - Worldwide 877-702-9580
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`IPR2014-00578 Zond Ex. 2012
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` JOHN BRAVMAN, Ph.D.
`plasma?
` A Yes.
` Q And would you also agree that Wang
`does not describe controlling voltage
`during such activities?
` A No.
` Q Can you point me where in Wang he
`describes controlling voltages when
`applying pulses to a plasma?
` A (Reviewing.)
` The worker of skill reading this
`and understanding the equipment that he's
`describing and the experimental regimes
`that he's describing, first of all, it's my
`opinion would absolutely understand that in
`a power supply for a sputtering or etching
`apparatus, that that would be completely
`expected.
` When he goes on to explain the
`various regimes of operation, that the --
`for instance, when you are in a quasistatic
`regime that the impedence is no longer
`changing in the chamber, that puts you to
`different operational regime.
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` JOHN BRAVMAN, Ph.D.
` All of these descriptions are
`consistent with the knowledge that one of
`skill in the art would immediately bring to
`reading this that a power supply doesn't
`have just a power control knob on it and at
`various times because power is a function
`of both voltage and current, a power supply
`is going to be controlling voltage and
`current to give you a desired power, if
`that's what you want it to do, especially
`in a situation where you have a rapidly
`changing impedence in the chamber, which
`you do, during ignition or during other
`events.
` Q So isn't it correct then that Wang
`is concerned with controlling the power
`that's applied to the plasma?
` MR. MAIER: Objection.
` Mischaracterizes his testimony.
` THE WITNESS: It is concerned
` with that, but it's also concerned
` with how you do that and how you do
` that is by controlling voltage and
` current.
`
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` JOHN BRAVMAN, Ph.D.
` And, again, my opinion is that a
` worker of skill would immediately
` understand that.
`BY MR. FAHMI:
` Q But you can't point me to anyplace
`in the text of the Wang patent itself that
`describes controlling voltage, right?
` A (Reviewing.)
` Well, in Figure 7 shows pulsed DC
`supply and it shows a fixed DC supply --
`well, Element 100 is a symbol for a
`variable battery, so that's controlling the
`voltage. It's got low-pass and high-pass
`filters in it.
` Figure 6 is the one that shows you
`power pulses, but Figure 7 shows you the
`schematic of a power supply that can supply
`both pulse and continuous DC voltages and
`there's nothing about Figure 7 that would
`direct a reader of skill to believe that
`anything other than it was a standard power
`supply in which you could control voltage
`and current and, in fact, had to for the
`device to function.
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`IPR2014-00578 Zond Ex. 2012
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` Q Well, isn't it true that the power
`supply 100 is not the power supply that is
`supplying power to the plasma?
` A Element 100 is a voltage source,
`and so it's part of the overall set of
`electronics that you would call a power
`supply. It is a variable power source.
` Q Isn't it true that power supply
`100 is actually connected to the target and
`supplies a constant negative voltage to the
`target?
` A Yes.
` Q So it doesn't supply power to the
`plasma, does it?
` MR. MAIER: Object to form.
` THE WITNESS: The plasma is
` powered by application of an
` electrical potential between the
` cathode and anode, whether it's a
` DC-fixed voltage or pulsed voltage.
`BY MR. FAHMI:
` Q Do you believe that power supply
`100 is connected -- connected between the
`cathode and anode?
`
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` JOHN BRAVMAN, Ph.D.
` A The anode is grounded, and the
`other side of power supply 100 is grounded,
`so yes.
` Q So it's your opinion that power
`supply 100 is supplying power to the
`plasma; is that right?
` A The patent talks about it may or
`may not. It's enough to -- let me find
`the -- (Reviewing.)
` It's enough to sustain the plasma.
`It may be low enough power that little
`sputtering actually occurs, but it's
`sustaining -- it's sustaining the plasma
`and that's its whole point and since the
`plasma can't be self-sustaining, it must be
`supplying sufficient power to the plasma to
`sustain it.
` Q Isn't the function of power supply
`100 to ignite the plasma?
` A That is one of its functions and
`-- and that's -- that's one of its
`functions.
` Q If you turn to Wang at column 5,
`and the passage that begins approximately
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` JOHN BRAVMAN, Ph.D.
`in line 23, continues to about line 28 or
`so, would you agree with me that Wang
`deemed that it was important that pulses
`have significant rise times?
` MR. MAIER: Object to form.
` THE WITNESS: I believe it
` characterizes that it may have a long
` rise time. I don't think it says it's
` desirable. It says the schematic
` drawing of perfectly rectangular
` pulses is not met as a worker of skill
` would understand and here or elsewhere
` it talks about the full-width at
` half-max of the actual waveform is
` designing its typical width.
`BY MR. FAHMI:
` Q Doesn't Wang indicate that
`significant rise times are actually
`expected?
` A It says that at line 26 or 7, yes.
`This is also in the context of one version
`of the -- one aspect of the invention where
`you don't have the background, so each
`pulse must ignite the plasma.
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`IPR2014-00578 Zond Ex. 2012
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` Q And in that context, actually,
`Wang is expecting relatively high voltages
`and pulses of over 50 microseconds; is that
`right?
` A It says in that same context
`citing an article by Chistyakov, that
`ignition may require over 50 microseconds.
` Q I have handed you this time what's
`been previously marked as Gillette's
`Exhibit 1002.
` Do you recognize this exhibit?
` A Yes.
` Q Do you recognize it as the Mozgrin
`reference that is referred to in your
`declaration?
` A Yes.
` Q If I refer to it as Mozgrin, will
`you understand that I am referring to
`Exhibit 1002?
` A Yes.
` Q When was the last time you had a
`chance to review the Mozgrin reference?
` A Last night.
` Q Would you agree with me that the
`
`TSG Reporting - Worldwide 877-702-9580
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`IPR2014-00578 Zond Ex. 2012
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` JOHN BRAVMAN, Ph.D.
`Mozgrin reference relates to a high-power
`quasi-stationary low-pressure discharge in
`a magnetic field?
` MR. MAIER: Object to form.
` THE WITNESS: What constitutes
` low pressure could be debated, but in
` general what you said is correct.
`BY MR. FAHMI:
` Q Why did you qualify that phrase
`"low pressure"?
` A It's in the title but when you're
`referring to things like "high current" or
`"low pressure," one of the metes and bounds
`of a current or pressure that is fairly
`labeled as such can be debated.
` Q Does Mozgrin provide any
`clarification about what was meant by "low
`pressure"?
` A Throughout the paper, he gives, in
`many instances, ranges of various
`parameters.
` Q Do you recall if pressure was one
`of them?
` A Yes, even in the second paragraph.
`
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`IPR2014-00578 Zond Ex. 2012
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` Q So as he's characterizing it in
`the second paragraph, would you agree that
`it's low pressure?
` A In the context of sputtering or --
`sorry, of plasmas, yes.
` Q Looking at page 401 of Mozgrin.
` A Okay.
` Q Mozgrin is reporting a study that
`uses two different discharge device
`configurations; is that right?
` A Yes, I see he does.
` Q And like Wang, Mozgrin also
`investigated these systems in the presence
`of a magnetic field; is that right?
` A Yes.
` Q In looking at the right column of
`page 401 in Mozgrin, would you agree that
`Mozgrin indicates that when employing a
`magnetic field in these contexts, the
`supply unit providing the square voltage in
`a current pulse with rise times or leading
`edges of five to 60 microseconds and
`durations as much as 1.5 milliseconds was
`needed?
`
`TSG Reporting - Worldwide 877-702-9580
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`IPR2014-00578 Zond Ex. 2012
`
`

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` JOHN BRAVMAN, Ph.D.
` MR. MAIER: Object to form.
` THE WITNESS: The particular
` supply unit that he apparently was
` using he describes with those
` parameters.
`BY MR. FAHMI:
` Q Does -- does Mozgrin describe the
`control of voltage pulses?
` A (Reviewing.)
` He reports on at least page 402
`what he calls oscillograms of voltage and
`current characteristics and also -- sorry,
`in Figures 3 and 4. I don't know if the
`phrase "control" is in here, but he's
`clearly indicating that those quantities
`must be known and I would opine controlled.
`He has in Figure 2, again, a power supply
`which indicates both a fixed and a variable
`components, so again my opinion is that a
`worker of skill would understand this in
`the context of plasma apparatus to be able
`to control voltage and current.
` Q Now, earlier, I think, you
`mentioned that when dealing with plasmas
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`IPR2014-00578 Zond Ex. 2012
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` JOHN BRAVMAN, Ph.D.
`and power pulses being applied to plasmas,
`impedence of the plasma changes; is that
`right?
` MR. MAIER: Object to form.
` THE WITNESS: Impedence of the
` plasma or the -- more properly, the
` space between the anode and cathode
` does change as a function of the
` conditions in the chamber, yes.
`BY MR. FAHMI:
` Q Why does that change and impedence
`takes place?
` A When you have neutral gas
`occupying a chamber, it's going to have a
`relatively high impedence and when you put
`a large enough electrical potential across
`that distance, at some point you will start
`generating ions and at that point, the
`connectivity, or more properly, the
`impedence of the gas will change
`significantly and this is part of the
`consideration for what we were speaking of
`a minute ago when we talk about firing the
`plasma or igniting the plasma and then, as
`
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`IPR2014-00578 Zond Ex. 2012
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`many of these papers discuss, it is
`advantageous to establish a regime where it
`does, in fact, as workers of skill know,
`and as Mozgrin shows, at least quasistatic
`behavior where it is relatively fixed, that
`is, the impedence is relatively fixed and
`you can establish a steady-state plasma.
` Q In the time when the impedence is
`changing, would you agree that it's
`preferable to control the power pulse width
`rather than a voltage or current pulse
`width?
` MR. MAIER: Objection to form.
` THE WITNESS: I don't see why
` actually that would be the case. Most
` power supplies are capable of
` developing far higher peak powers than
` steady-state powers and so the concern
` would be controlling the voltage as a
` function of the current or current, I
` should say, as a function of voltage
` to establish that desirable
` quasistatic case. I don't see why one
` would posit what you did.
`
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`IPR2014-00578 Zond Ex. 2012
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`BY MR. FAHMI:
` Q Well, let me invite your attention
`to the Wang reference in column 5, about
`line 51 or so.
` A (Reviewing.)
` Q Doesn't Wang indicate that when
`the chamber impedence is changing, the
`power pulse width is preferably the one
`that is specified?
` A He does in that instance, yes.
`And this was the full-width at half-max
`that I was referring to earlier. I
`couldn't find it before.
` Q So this time I have handed you a
`copy of what's been previously marked as
`Gillette's Exhibit 1003, and do you
`recognize this exhibit?
` A Yes.
` Q Do you recognize it as what I
`think we commonly refer to as the
`Kudryavtsev reference?
` A Yes.
` Q And it's the same Kudryavtsev
`reference that's being discussed in your
`
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`declaration; is that right?
` A Yes.
` Q It's one of the references, in
`fact, that you considered during the
`preparation of that declaration, is it not?
` A Yes.
` Q When is the last time you had a
`chance to review this exhibit?
` A Last night.
` Q The experimental system which
`Kudryavtsev reports on in this paper did
`not use a magnetic field, did it?
` A That is correct. The data that he
`reports on was obtained in a system without
`a magnetic field.
` Q And in Figure 3 of Kudryavtsev, he
`reports pressures of 3.7 torr and 11.4
`torr; is that right?
` A Yes.
` (Reviewing.)
` I'm sorry, where is the reference?
` Yes. I see it. You're absolutely
`right.
` Q Let's take a look at the claims of
`
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