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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---------------------------------------------------------------X
`THE GILLETTE COMPANY, et al.,
` Patent No. 8,125,155
` Petitioners, IPR 2014-00477
` IPR 2014-00479
` -against-
`ZOND, LLC, Patent No. 7,808,184
` IPR 2014-00799
` IPR 2014-00803
` PATENT OWNER.
`---------------------------------------------------------------X
`
` VIDEOTAPED DEPOSITION OF
` JOHN BRAVMAN, Ph.D.
` Lewisburg, Pennsylvania
` Tuesday, April 21, 2015
`
`Reported by:
`Rebecca Schaumloffel, RPR, CLR
`Job No: 92739
`
`TSG Reporting - Worldwide 877-702-9580
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`Gillette v. Zond
`IPR2014-00799
`Exhibit 1034
`
`

`
`A P P E A R A N C E S:
`
` WILMERHALE
` Attorneys for the Petitioner
` 7 World Trade Center
` 250 Greenwich Street
` New York, New York 10007
` BY: COSMIN MAIER, ESQ.
` YUNG-HOON HA, ESQ.
`
` CHAO HADIDI STARK & BARKER
` Attorneys for the Patent Owner, Zond
` 176 East Main Street
` Westborough, Massachusetts 01581
` BY: BRUCE BARKER, ESQ.
`
` ALSO PRESENT:
`
` Larry Moskowitz, Legal Videographer
` David Tennant, Esq., White & Case
` (Telephonically)
`
` * * *
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`Page 2
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` April 21, 2015
` 9:04 a.m.
`
` Videotaped deposition of JOHN
`BRAVMAN, Ph.D, held at the BEST WESTERN PLUS
`COUNTRY CUPBOARD INN, 7701 West Branch
`Highway, Lewisburg, Pennsylvania, before
`Rebecca Schaumloffel, a Registered
`Professional Reporter, Certified Livenote
`Reporter and Notary Public of the States of
`New York, New Jersey, and Pennsylvania.
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`1
` J. BRAVMAN
`2
` THE VIDEOGRAPHER: Good morning.
`3 We are now on the record. This is the
`4
`start of tape label one of the
`5
`videotaped deposition of John Bravman,
`6
`ph.D in the matter the Gillette
`7
`Company versus Zond, Inc. This
`8
`deposition is being held at the Best
`9 Western, 7701 West Branch Highway,
`10
`Lewisburg, Pennsylvania on April 21,
`11
`2015, at approximately 9:05 a.m.
`12
` My name is Larry Moskowitz from
`13
`TSG Reporting Inc., and I am the legal
`14
`video specialist. The reporter is
`15
`Rebecca Schaumloffel, also in
`16
`association with TSG Reporting. Will
`17
`counsel please introduce themselves
`18
`for the record.
`19
` MR. BARKER: Bruce Barker of
`20
`Chao, Hadidi, Stark & Barker for Zond.
`21
` MR. MAIER: Cosmin Maier of
`22 Wilmer Hale for petitioner, the
`23 Gillette Company, and with me is my
`24
`colleague Sam Ha.
`25
`
`1
` J. BRAVMAN
`2
`J O H N B R A V M A N, called as a
`3 witness, having been first duly sworn by a
`4 Notary Public of the State of New York, was
`5
`examined and testified as follows:
`6
`EXAMINATION BY
`7 MR. BARKER:
`8
` Q. Good morning, Mr. Bravman.
`9
` A. Good morning.
`10
` Q. As you heard, I am Bruce Barker
`11
`representing Zond, and I will be asking you
`12
`some questions this morning about the
`13 Declaration you submitted in this case.
`14
` But let me start by saying that I
`15
`noticed from your resume that you have been
`16
`deposed on many occasions before; is that
`17
`correct?
`18
` A. Yes.
`19
` Q. So you are familiar with the
`20
`procedure; I can assume that?
`21
` A. Yes.
`22
` Q. Okay. Then let's just start with
`23
`some aspects of your background. I noticed
`24
`in paragraph 3 of your Declaration that you
`25 were once on the faculty at Stanford
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`1
` J. BRAVMAN
`2 University; is that correct?
`3
` A. Yes. Yes, that's right. I was
`4
`at Stanford on the faculty there.
`5
` Q. I assume you gave class lectures
`6
`or taught courses as a faculty member?
`7
` A. Yes.
`8
` Q. Just describe generally some of
`9
`the subject matter of those courses?
`10
` A. Yes. I taught undergraduates and
`11
`graduate students from introductory to
`12
`advanced level. I taught courses involving
`13
`basic material science. I taught courses on
`14
`structure of matter, the analysis of matter,
`15
`and the fabrication of integrated circuits.
`16
`That probably covers generally what I taught.
`17
` Q. Did you teach any courses in
`18
`control system theory?
`19
` A. Not a course I recall control
`20
`system, no.
`21
` Q. Did the topic of control systems
`22
`ever come up in any of the courses that you
`23
`did teach?
`24
` A. I probably, in certain contexts,
`25
`described control of systems that we either
`
`Page 8
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`1
` J. BRAVMAN
`2
`used or designed and built. We built much
`3
`specialized equipment for materials analysis
`4 which -- which included control systems of a
`5
`variety of types, but I don't think I taught
`6
`courses on that specifically.
`7
` Q. Okay. So to make sure I
`8
`understand, in connection with those courses,
`9
`you and your students designed certain
`10
`systems; that what I heard you say?
`11
` A. No, in my research group, we
`12
`designed and built specialized test equipment
`13
`of a variety of types. I was speaking to
`14
`your question about actual formal course
`15 work.
`16
` Q. Okay. So those systems that you
`17
`designed, I assume they included electronic
`18
`controllers; is that correct?
`19
` A. Yes.
`20
` Q. Did you purchase those
`21
`controllers off the shelf, or did you design
`22
`them yourself?
`23
` A. We purchased components, and we
`24
`purchased systems as well. So depending on
`25 what we were designing and building, we did
`Page 9
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`1
` J. BRAVMAN
`2
`both.
`3
` Q. Can you generally describe for me
`4
`some of the parameters that were controlled
`5
`by those control systems?
`6
` A. Voltages, currents, temporal
`7
`conditions, movement of physical objects via
`8 motors and feedback controls. So positioning
`9
`systems. Three-dimensional positioning
`10
`systems. Gas flow. There also were sensors
`11
`and measurements involved with those as well.
`12
` Q. Now, you mentioned feedback
`13
`controllers. Did any of your control systems
`14
`use an open-loop approach?
`15
` MR. MAIER: Object to form.
`16
` A. I want to answer precisely. So
`17 what exactly do you mean by open-loop?
`18
` Q. Well, are you familiar with the
`19
`term open-looped control system?
`20
` A. Sure, I have heard that phrase
`21 many times.
`22
` Q. I am referring to that.
`23
` A. Okay. I can't answer -- I just
`24
`don't recall at this point. I mean these are
`25
`systems that we designed over a two-decade
`
`1
` J. BRAVMAN
`2
`timeframe. But it's been awhile.
`3
` Q. Okay. But do you remember the
`4
`feedback control systems that you mentioned
`5
`earlier?
`6
` A. Some of our systems had feedback
`7
`control and some did not.
`8
` Q. Okay. So those that did not have
`9
`feedback control systems, it seems like
`10
`you're not prepared to characterize them as
`11
`open-loop. How would you characterize those
`12
`controllers?
`13
` MR. MAIER: Object to form.
`14
` Mischaracterizes the witness's
`15
` testimony.
`16
` A. Open-loop systems don't include
`17
`feedback, typically. But I was asking
`18
`specifically because I wanted to give a
`19
`specific answer. We had systems that were as
`20
`simple as observing through an observation
`21
`port and holding our finger on a button, and
`22 we had other systems where, especially when
`23
`they were running for days on end, where we
`24
`had at least moderately sophisticated sensors
`25
`and feedback loops. They were generally in a
`3 (Pages 6 to 9)
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` J. BRAVMAN
`2
`day programmed in Fortran and had computer
`3
`controllers. I lived through the period of
`4
`personal computers becoming available, and we
`5
`started programming personal computers with
`6
`pre-packaged software that made it a lot
`7
`easier than writing our own code. So by
`8 working through the 80s, 90s and 2000
`9
`timeframe, I lived through that transition
`10
`from coding ourselves to being able to use
`11
`code that was written for us. National
`12
`Instruments was a big supplier of said code.
`13
`This made programming easier. So we were
`14
`involved in a spectrum of those activities.
`15
` Q. So the code you referred to, this
`16 was code for a control system; is that
`17
`correct?
`18
` A. It was -- it could be often
`19
`adopted for many purposes. But it was for
`20
`control and measurement. Feedback, it was
`21
`for data collection, data analysis. I mean,
`22 we built over the decades more and more
`23
`sophisticated systems.
`24
` Q. Now, in the equipment you
`25
`referred to, did any of it involve power
`
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` J. BRAVMAN
`supply design?
` A. We had power supplies in much of
`our equipment of a variety of types because
`of what we were doing. So, yes.
` Q. Again, did you purchase those
`power supplies off the shelf, or did you
`custom design your own?
` A. In some of our equipment, we just
`designed our own and used -- and bought basic
`components, transformers, capacitors,
`resistors, switches inductors, other systems
`as the requirements grew more stringent, and
`depending on the availability of research
`dollars, I know that we bought power
`suppliers as well.
` Q. Now, for the power supplies that
`you designed yourself, did they include a
`control system?
` A. Yes. I mean, the power supply
`for anything but the simplest application
`needs to have some measure of control
`starting with on/off switch and getting more
`sophisticated depending on what was required.
` Q. What would you call the component
`Page 13
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` J. BRAVMAN
`2
`that provides that control; can we use a
`3
`reference, would you call it controller?
`4
` MR. MAIER: Objection to form.
`5
` A. I have been using component to
`6 more narrow -- a definition typically, a
`7
`component such as a transformer or capacitor
`8
`and assembly of components often would be
`9
`called a controller.
`10
` Q. Okay. Now, how about did you
`11
`offer any courses, this is in the Stanford
`12
`timeframe now, any course in plasma physics?
`13
` A. I offered courses that had
`14
`lectures on plasma physics but never a course
`15 with that in the title.
`16
` Q. Now, I noticed in your
`17 Declaration that you are currently, among
`18
`other things, a professor of electrical
`19
`engineering at Bucknell; is that correct?
`20
` A. Yes.
`21
` Q. Now, are you teaching courses
`22
`there?
`23
` A. I only give guest lectures. I
`24
`don't teach regular courses because of my
`25
`full-time position.
`
`1
` J. BRAVMAN
`2
` Q. How about in the past, have you
`3
`previously taught courses at Bucknell?
`4
` A. No, I moved here in 2010 to
`5
`become president of the University and was
`6
`simultaneously appointed professor of
`7
`electrical engineering.
`8
` Q. What were some of the topics of
`9
`the guest lectures you gave?
`10
` A. I taught about crystal structure,
`11 materials analysis, history of the Internet,
`12 Moore's Law, the acceleration of
`13 microelectronic technology. I have also
`14
`talked about cardiac stents because I have
`15
`patents in those areas.
`16
` Q. Did you ever give any lectures on
`17
`control systems or control theory?
`18
` A. Here at Bucknell?
`19
` Q. Yes.
`20
` A. No.
`21
` Q. Now, at the end of your resume, I
`22
`noticed that sometime in 2013, you began
`23
`representing -- you worked as a testifying
`24 witness in the Intel versus Zond patent
`25
`litigation; is that correct?
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` A. Yes, I was retained for that
`3
`position, yes.
`4
` Q. So I assume that was Intel that
`5
`retained you?
`6
` A. Correct.
`7
` Q. And you say here 2013. Do you
`8
`know -- can you recall the month in which
`9
`that began?
`10
` A. No.
`11
` Q. Now, did you sign a Retainer
`12 Agreement with Intel?
`13
` MR. MAIER: Objection;
`14
` relevance.
`15
` A. I am sure I did.
`16
` Q. Do you recall what the -- your
`17
`rate was for that engagement?
`18
` MR. MAIER: Objection;
`19
` relevance.
`20
` A. My standard rate is $450 an hour.
`21
` Q. You are speaking in the present
`22
`tense. I am referring back to the time in
`23
`2013 when you were retained.
`24
` Are you saying it was the same
`25
`rate then?
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`2
` MR. MAIER: Same objection.
`3
` A. To the best of my memory, I have
`4
`not increased my rates. My rates have been
`5
`flat for many years.
`6
` Q. Now, directly beneath that, I see
`7
`you have also been retained by Gillette in
`8
`this IPR; is that correct?
`9
` A. That's correct.
`10
` Q. And do you recall what month that
`11
`you were retained by Gillette?
`12
` A. It was this year. It was -- I
`13
`think it was January but I don't recall.
`14
` Q. Okay. So it may be -- let me
`15
`give you your CV. I think there may be a
`16 mistake on that.
`17
` Mr. Bravman, I am going to hand
`18
`you a copy of your Declaration marked
`19 Gillette 1026 and IPR 2014-00477.
`20
` MR. MAIER: I will correct for
`21
` the record, it is Dr. Bravman. I
`22
` think you have been calling him Mr.
`23
` MR. BARKER: I will try to
`24
` correct that.
`25
` Q. But you respond to Mr. Bravman as
`Page 17
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` J. BRAVMAN
`2 well, assume?
`3
` A. Yes, sir. People call me all
`4
`sorts of things.
`5
` Q. I will do my best. I am inviting
`6
`your attention to page 11 of your resume
`7
`attached to the back of this Declaration.
`8
` A. I see it.
`9
` Q. It says here -- this time span
`10
`specified for your representation of Gillette
`11
`is 2013 to present; is that correct?
`12
` A. I see that there. That's
`13
`definitely a typo. I would have to look at
`14 my -- I cut and pasted probably from the
`15
`Intel case above.
`16
` Q. Okay. So do you -- do you recall
`17
`roughly when you did first begin representing
`18 Gillette in this matter?
`19
` A. As I indicated, I believe it was
`20
`in this year, calendar year 2015. But I
`21 would have to check when I signed the
`22 Declaration.
`23
` Q. Now, have you been retained by
`24
`any of the other petitioners in these IPRs?
`25
` A. Well, I was with Intel, as you
`
`1
` J. BRAVMAN
`2
`pointed out.
`3
` Q. Any others?
`4
` A. I know there are quite a few. I
`5
`believe I signed on with TSMC, and before I
`6
`did any work whatsoever, that that case, to
`7 my memory, was, I don't know if settled is
`8
`the right phrase, but I knew I would not have
`9
`any ongoing engagement so there was no
`10
`billing in that case. And that was sometime
`11
`in this calendar year as well, I believe.
`12
` Q. Did you actually get to the point
`13 where you signed an engagement letter with
`14
`them?
`15
` A. I think I did. I think I recall
`16 writing to somebody, well, that's the
`17
`shortest engagement I have had. Because,
`18
`literally, within a day or three, from
`19 memory, it was a very short period of time, I
`20 was told that my involvement, at least, was
`21
`over.
`22
` Q. Other than Intel, Gillette, and
`23
`TSMC, have you been retained by any other
`24
`petitioners in the IPRs against Zond?
`25
` A. You know, there is an issue with
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` J. BRAVMAN
`2 GlobalFoundries but I -- from memory, I can't
`3
`tell you the status of my involvement there;
`4 whether or not I have signed or will be asked
`5
`to sign an engagement. In one of my
`6
`declarations, there is a long list of
`7
`entities on the cover but the ones I
`8
`specifically remember are Intel which we have
`9
`talked about, Gillette, of course, and TSMC
`10
`that I just indicated.
`11
` Q. Okay. Just to make sure I
`12
`understand, you have had some contact with
`13 GlobalFoundries but has not yet matured into
`14
`a formal engagement; is that correct?
`15
` A. What I said was, I honestly can't
`16
`remember if I have signed a nondisclosure or
`17
`not. That's the only other specific company
`18
`name that in addition to Intel, Gillette, and
`19
`TSMC that I can recall as a possibility.
`20
` Q. So your representation of Intel
`21
`began years earlier in 2013, correct?
`22
` A. I believe that's the correct
`23
`date, yes.
`24
` Q. Back in that timeframe, the 2013
`25
`timeframe, did you have any contact with
`
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`1
` J. BRAVMAN
`2 Gillette, TSMC or any of the other
`3
`petitioners in these IPRs?
`4
` MR. MAIER: Objection;
`5
` relevance.
`6
` A. Not to my memory, no.
`7
` Q. Dr. Bravman, I am going to hand
`8
`you a copy of U.S. Patent 8,125,155
`9
`previously marked as exhibit Gillette 1001.
`10
` A. Thanks.
`11
` Q. Now, I notice in paragraph 10 of
`12
`your Declaration, you say you reviewed that
`13
`patent. Can you tell me, when was the last
`14
`time that you read it?
`15
` A. Last night.
`16
` Q. And did you read it in its
`17
`entirety last night?
`18
` A. No. It is a long patent.
`19
` Q. Have you ever read it in its
`20
`entirety?
`21
` A. Yes.
`22
` Q. When is the first time you think
`23
`you read it from beginning to end?
`24
` A. January or February of this year,
`25
`I believe.
`
`Page 21
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` J. BRAVMAN
` Q. And how much time would you say
`you have spent studying or otherwise reading
`the patent since you first picked it up?
` A. I don't recall how many hours I
`have billed but it's probably on the order of
`75 to 100 hours in this matter so far.
` Q. Well, this matter involves other
`issues such as prior art and in other
`patents, correct?
` A. Yes.
` Q. So I am trying to focus on the
`amount of time you devoted to familiarizing
`yourself with the subject matter of the '155
`Patent?
` MR. MAIER: Objection to form to
` the extent there was a question.
` Q. That was just giving you a sense
`of what I am looking for. My question is,
`can you tell me how much time you have
`devoted specifically to understanding the
`subject matter of Patent number 8,125,155?
` A. The way I work is often in blocks
`of time where I am focusing on multiple
`documents especially in the matter such as
`
`1
` J. BRAVMAN
`2
`this. So I would be, you know, only
`3
`estimating there. There is four patents in
`4
`this matter that I have been involved with.
`5
`Two of them are very, very similar. And the
`6
`specification is nearly identical or
`7
`identical. I am sure it is on the order of
`8
`ten to fifteen 15 hours, at least.
`9
` Q. And did you understand the patent
`10 when you studied it?
`11
` A. Depends what you mean by
`12
`understand but, yes, I believe I did. I came
`13
`to understand and especially for this matter
`14
`how a worker skilled in the timeframe of the
`15
`patent would understand it, yes.
`16
` Q. Well, would you mind turning to
`17
`Figure 1 of the patent.
`18
` A. Okay.
`19
` Q. And in particular, I want to
`20
`direct your attention to the component
`21
`labeled power supply, "Pulsed Power Supply
`22
`102"?
`23
` A. I see.
`24
` Q. I want to explore your
`25
`understanding. Let's begin by, can you
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` J. BRAVMAN
`identify for me the outputs of the pulsed
`power supply 102?
` A. Well, it is showing a number
`indicator 120 as some kind of connection,
`presumably electrical connection, to some
`other piece of the apparatus inside the
`chamber.
` Q. And that's an output terminal, is
`that what you are telling me?
` A. I have to look and see how it is
`labeled. But the only thing that's in this
`drawing connecting the pulsed power supply
`102 to the rest of the apparatus is a line
`that's labeled 122 and it has a terminus at
`label number 120.
` Q. What about the other signal
`labeled 125?
` A. 125 is the ground.
` Q. Okay. Now, I notice there is --
` A. I would like to look at the
`patent for a moment.
` In column 2, line 58 or so, it
`indeed indicates that first terminal 120 of
`the pulsed power supply 102 with electrical
`Page 24
`
`1
` J. BRAVMAN
`2
`transmission line 122. So that's consistent
`3 with what I was answering before.
`4
` Q. So did I understand you that
`5
`that's an output of the pulsed power supply?
`6
` A. It is an output that's going to
`7
`the chamber. One understands that with a
`8
`pulse signal, you have -- in any electrical
`9
`circuit, you have to have a circuit. So the
`10
`other pieces to ground which is indicated by
`11
`the symbol 105.
`12
` Q. Now, I don't see any other
`13
`terminals. So am I correct that there are no
`14
`external inputs into the pulsed power supply
`15
`in 102 shown in Figure 1?
`16
` MR. MAIER: Objection to form.
`17
` A. The figure schematically shows
`18
`relevant pieces of what the power supply is.
`19
`It doesn't, for instance, show that it is
`20
`plugged into a wall, and it has to be plugged
`21
`into a wall to work. And by plugged into a
`22 wall, it has to have it its own source of
`23
`presumably A/C power. So it shows
`24
`schematically certain aspects of itself and
`25
`certain features, but that's schematically
`
`Page 25
`
`1
` J. BRAVMAN
`2 what it shows here. It shows only two
`3
`electrical wires schematically.
`4
` Q. Okay. So having read the
`5
`specification, what's your understanding of
`6
`the -- strike that.
`7
` Based upon your reading of the
`8
`'155 Patent and how it describes the
`9
`operation of that pulsed power supply 102,
`10
`can you describe for me generally what
`11
`structural components would be in the pulsed
`12
`power supply 102?
`13
` MR. MAIER: Objection to form.
`14
` A. Pulsed power supplies of this
`15
`type generally include transformers,
`16
`capacitors, inductors, switches, wiring, and
`17
`then perhaps other features. But any power
`18
`supply would have those components.
`19
` Q. How about a controller?
`20
` MR. MAIER: Objection to form.
`21
` Q. Let me rephrase that. Would,
`22
`based upon your understanding of the '155
`23
`Patent disclosure and your knowledge in the
`24
`art, would you expect that the pulsed power
`25
`supply 102 to include a controller in
`
`1
` J. BRAVMAN
`2
`addition to the items you just mentioned?
`3
` MR. MAIER: Objection;
`4
` foundation, form.
`5
` A. As I indicated, I believe,
`6
`earlier, what constitutes or comprises a
`7
`controller could vary from something as
`8
`simple as on/off switches to something quite
`9
`sophisticated. So, yes, I would expect there
`10 would be some means of controlling the power
`11
`supply's output, especially given that it is
`12
`labeled a pulsed power. So there has to be
`13
`something controlling when those pulses
`14
`start, stop, and other features that would be
`15 well understood to workers of skill. They
`16
`are not indicated in the schematic but one
`17
`presumes that, like many things not in the
`18
`schematic, they would be present.
`19
` Q. So you mentioned that capacitors
`20
`and transformers, are those for storing
`21
`energy in the pulsed power supply?
`22
` A. Capacitors by their very nature,
`23
`as do inductors, store energy. They serve
`24 many purposes but they store energy.
`25
` Q. Now, the switches you mentioned,
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` J. BRAVMAN
`2
`are they operated by the control that you
`3 mentioned to deliver stored energy to the
`4
`output terminals?
`5
` MR. MAIER: Objection to form;
`6
` foundation.
`7
` A. I don't believe there is
`8
`sufficient detail in the '155 Patent's
`9
`description to answer that question. There
`10
`are power supplies that -- for which the
`11
`answer to that question would be yes and
`12
`other simpler power supplies which the answer
`13 would probably be no.
`14
` Q. Let's look at paragraph 59 of
`15
`your Declaration, please.
`16
` A. Okay.
`17
` Q. In particular, I want to direct
`18
`your attention to the sentence that says,
`19
`"The '155 Patent teaches that the amplitude
`20
`and rise time of the voltage pulse is
`21
`indirectly controlled by setting a different
`22
`parameter - the power mode."
`23
` Do you see that?
`24
` A. Yes.
`25
` Q. So the power mode you are
`
`Page 28
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` J. BRAVMAN
`referring to here, is that a condition of the
`pulsed power supply 102 in Figure 1 we have
`been discussing?
` MR. MAIER: Object to form.
` A. Sorry, it is a condition of the
`power supply?
` Q. Is it a mode of the pulsed power
`supply 102?
` MR. MAIER: Object to form.
` A. Well, as it says in the sentence
`there, coming from the patent, it's a
`parameter is set in the power mode and
`various power supplies, controllers, are
`configured or designed to allow the user to
`select or control within bounds various
`parameters such as power delivered.
` Q. Okay. I want to explore more
`your understanding of this power mode
`feature, and I want to start with a very
`simple question. The power mode referred to
`here in your Declaration, does that refer to
`a state or a condition of the pulsed power
`supply 102?
` MR. MAIER: Objection to form.
`
`Page 29
`
`1
` J. BRAVMAN
`2
` A. So the power that a power supply
`3
`delivers is a function broadly of both its
`4
`ability to apply a voltage across an
`5
`impedence. The result of which will be the
`6
`current and the result of that will be a
`7
`power that is applied. So a power supply
`8
`can't, in the abstract, produce a power. It
`9
`needs a load over which it applies a voltage
`10 within certain bounds. It will be able to
`11
`deliver a current and, therefore, depending
`12
`on the voltage and current, will produce
`13
`power. All those are time dependent and may
`14
`have other dependencies as well. So that's
`15 when you select power mode, you are, I
`16
`believe, generically indicating to a system
`17
`that your set point is around the production
`18
`of a certain power. You can't have power in
`19
`the abstract without actually feeding a load.
`20
` Q. What's the set point you are
`21
`referring to?
`22
` A. Well, I am using that generically
`23
`there. If something is in the power mode and
`24
`you have a system which you tell to deliver
`25
`100 watts of power, if it is properly
`
`1
` J. BRAVMAN
`2
`designed, built, and operated, it will seek
`3
`to apply enough voltage across the load with
`4
`a certain impedence that will eventuate in
`5
`100 watts being delivered.
`6
` Q. So in this example, the set point
`7 was specified as target power; is that
`8
`correct?
`9
` MR. MAIER: Objection to form;
`10
` mischaracterizes testimony.
`11
` A. I just used the word set point
`12
`generically. When it is in power mode, I
`13
`presume that to mean the author meant that he
`14 was setting power somehow. In a very simple
`15
`system, it may be by manual control. In a
`16 more sophisticated system, it would have to
`17
`include sensors and feedback loops and so
`18
`forth.
`19
` Q. So but I am trying to get an
`20
`understanding to make sure we are on the same
`21
`page with terminology.
`22
` A. Okay.
`23
` Q. I want to get an understanding of
`24
`the term set point. That is a commonly used
`25
`term in a control systems; am I correct?
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`2
` MR. MAIER: Objection;
`3
` foundation.
`4
` A. I generically understand what set
`5
`point means and not just in power systems.
`6
`It's an indication of a desired outcome.
`7 Whether or not that outcome is met or
`8 maintained depends on many factors.
`9
` Q. Is a set point a common parameter
`10
`in a controller?
`11
` MR. MAIER: Objection;
`12
` foundation, form.
`13
` A. It's common in some that have
`14
`feedback loops. You can't have a set point
`15 without a feedback loop.
`16
` Q. Why is that?
`17
` MR. MAIER: Same objections.
`18
` A. Without a feedback -- without a
`19
`feedback loop, a system cannot know if it is
`20
`over or undershooting the so-called set point
`21
`and then correct its available output
`22
`functions to bring the measure parameter in
`23
`line with the desired parameter which one
`24 might call a set point.
`25
` Q. Well, in an open-loop control
`
`Page 32
`
`1
` J. BRAVMAN
`2
`system, what term would you then use to refer
`3
`to the desired value provided as an input to
`4
`the controller?
`5
` A. That's why I indicated before,
`6
`that set point I was using just generically
`7
`as synonymous with something you just said,
`8
`the desired value. In a true feedback
`9
`system, a set point takes on a more specific
`10 meaning to a worker of skill. But you can't
`11
`have a true -- you can't have a system that
`12 maintains a set point without sensors and
`13
`feedback systems.
`14
` Q. I think you missed my question,
`15 which was, in an open-looped control system,
`16 what term would you use to refer to the
`17
`desired value provided as an input to the
`18
`controller?
`19
` MR. MAIER: Object to form.
`20
` A. I might use -- I am trying to
`21
`think of phrases that we used. What somebody
`22 would say things like what is the target
`23
`voltage in this system, what is the target
`24
`power.
`25
` Q. So target voltage or target since
`
`Page 33
`
`1
` J. BRAVMAN
`2 we are speaking generically.
`3
` A. A target is something you aim
`4
`for, you aim at it generically in the English
`5
`language. So we are aiming for this
`6
`condition. We are aiming for this
`7
`temperature. We are aiming for this current
`8
`flow.
`9
` But without a feedback system, it
`10
`is something that we would have to manually
`11
`control.
`12
` Q. I want to get back to the power
`13 mode. Now, in paragraph 59 of your
`14 Declaration, like the third line on Page 24.
`15
` A. Yes.
`16
` Q. You make reference to the power
`17
`supply, referred to the power supply 102 in
`18
`Figure 1 operates in a low-power mode. Can
`19
`you describe for me what your understanding
`20
`of that language is, what does it mean for
`21
`the power supply 102 to quote operate in a
`22
`low-power voltage mode?
`23
` MR. MAIER: Object to form.
`24
` A. I believe what it's -- in the
`25
`context of the '155 Patent, since low and
`
`1
` J. BRAVMAN
`2
`high power are obviously not absolute values,
`3
`it is referring to maintaining the plasma in
`4
`an excited or pre -- often described as
`5
`pre-ionized state. It is also called a
`6 weakly-ionized plasma.
`7
` Q. Well, let me invite your
`8
`attention to column 12, line 20. I would
`9
`like you to read lines 20 to 22. In fact,
`10 why don't I read them for the record.
`11
` Quote, "Since there is
`12
`insufficient energy stored in the pulsed
`13
`power supply in the low-power mode to create
`14
`conditions that can sustain a
`15
`strongly-ionized plasma."
`16
` Does that language suggest to one
`17
`skilled in the art that the low-power mode of
`18
`the power supply 102 refers to the capacity
`19
`of the power supply to deliver energy?
`20
` MR. MAIER: Object to form.
`21
` A. That sentence fragment that you
`22
`read indicates that, as he has described the
`23
`particular power supply, it can maintain this
`24 weakly-ionized plasma but not a
`25
`strongly-ionized plasma.
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` J. BRAVMAN
`2
` Q. I am referring to the language
`3
`that talks about the insufficient energy
`4
`stored in the supply.
`5
` What's your understanding of that
`6
`language?
`7
` MR. MAIER: Objection to form.
`8
` A. Well, the sentence goes on to
`9
`explain, I believe, what that m