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` OVERZET - 5/7/15
` UNITED STATES PATENT AND TRADEMARK OFFICE
` -----------------------------------------
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` -----------------------------------------
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY,
`LTD., TSMC NORTH AMERICA CORPORATION, FUJITSU
`SEMICONDUCTOR LIMITED, FUJITSU SEMICONDUCTOR
`AMERICA, INC., ADVANCED MICRO DEVICES, INC.,
`RENESAS ELECTRONICS CORPORATION, RENESAS
`ELECTRONICS AMERICA, INC., GLOBALFOUNDRIES
`U.S., INC., GLOBALFOUNDRIES DRESDEN MODULE ONE
`LLC & CO., KG, GLOBALFOUNDRIES DRESDEN MODULE
`TWO LLC & CO., KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA
`AMERICA INFORMATION SYSTEMS, INC., TOSHIBA
`CORPORATION, and THE GILLETTE COMPNAY,
`
` Petitioners,
`vs.
`ZOND, LLC,
` Patent Owner.
` Patent 7,811,421 B2
`--------------------------------------------
` IPR Case Nos. IPR2014-00800, 00802, 00805
`--------------------------------------------
`
` VIDEOTAPED DEPOSITION OF
` LAWRENCE J. OVERZET PH.D.
` DALLAS, TEXAS
` MAY 7, 2015
`
`Reported by: Susan S. Klinger, RMR-CRR, CSR
`Job No. 93304
`
`TSG Reporting - Worldwide 877-702-9580
`
`Fujitsu et. al. v. Zond IPR2014-00800
`Page 1 Zond Ex. 2018
`
`

`

`Page 2
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`Page 3
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`1
` OVERZET - 5/7/15
`2 A P P E A R A N C E S:
`
`34
`
`Attorneys for GlobalFoundries:
`5
` Mr. David Tennant, Esq.
`6
` Mr. Brett Rismiller, Esq.
`7
` WHITE & CASE
`8
` 701 Thirteenth Street, N.W.
`9
` Washington, D.C. 20005
`10
`11 Attorneys for Toshiba:
`12
` Mr. Robinson Vu, Esq.
`13
` BAKER BOTTS
`14
` 910 Louisiana Street
`15
` Houston, Texas 77002
`16
`17 Attorneys for Defendant(s):
`18
` Mr. Bruce Barker, Esq.
`19
` CHAO HADIDI STARK & BARKER
`20
` 176 East Main Street
`21
` Westborough, Massachusetts 01581
`22
`23 Also Present:
`24
` Mr. Jay Wiggins, videographer
`25
`
`Page 5
`
` OVERZET - 5/7/15
`
` May 7, 2015
` 9:08 a.m.
`
` Deposition of LAWRENCE J. OVERZET, PH.D.,
`held at the offices of Baker Botts, 2001 Ross
`Avenue, Dallas, Texas, before Susan S. Klinger,
`a Registered Merit Reporter and Certified
`Realtime Reporter of the State of Texas.
`
`Page 4
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` OVERZET - 5/7/15
`2
` VIDEOGRAPHER: This is the start of
`3
`tape labeled number 1 in the deposition of
`4 Dr. Overzet in the matter of Gillette
`5
`Company versus Zond, Incorporated in the
`6
`court of the United States Patent and
`7
`Trademark Office, patent number 7,811,421
`8
`B2, IPR case numbers 2014-8 -- I'm sorry,
`9
`-00800, 00802, 00805. This deposition is
`10
`being held at Baker Botts, 2001 Ross
`11 Avenue, Dallas, Texas on May 7th, 2015 at
`12
`approximately 9:09 a.m.
`13
` My name is Jay Wiggins. I'm a
`14
`representative of -- I am a legal video
`15
`specialist representing TSG Reporting,
`16
`Incorporated headquartered at 747 Third
`17 Avenue, New York, New York. The court
`18
`reporter is Susan Klinger in association
`19 with TSG Reporting.
`20
` Will counsel please introduce
`21
`yourself.
`22
` MR. BARKER: My name is Bruce Barker
`23
`of Chao Hadidi Stark & Barker, and I
`24
`represent the patent owner, Zond.
`25
` MR. TENNANT: My name is David
`
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` OVERZET - 5/7/15
` Tennant of White & Case. I represent
` GlobalFoundries.
` VIDEOGRAPHER: Will the court
` reporter please swear in the witness. Oh,
` I'm sorry. Other parties may introduce
` themselves.
` MR. RISMILLER: My name is Brett
` Rismiller with White & Case, also for
` GlobalFoundries.
` MR. VU: Robinson Vu with Baker
` Botts representing Toshiba.
` MR. RISMILLER: Is there anyone
` online?
` MR. TENNANT: Bruce, just real
` quick, any objections that are made today
` will apply to all petitioners.
` MR. BARKER: That's fine.
` DR. LAWRENCE OVERZET,
`having been first duly sworn, testified as
`follows:
` EXAMINATION
`BY MR. BARKER:
` Q. Good morning, Dr. Overzet. As you
`heard, my name is Bruce Barker. I represent
`2 (Pages 2 to 5)
`
`TSG Reporting - Worldwide 877-702-9580
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`Fujitsu et. al. v. Zond IPR2014-00800
`Page 2 Zond Ex. 2018
`
`

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` OVERZET - 5/7/15
`Zond, and I'm going to be asking you some
`questions today about a declaration you
`prepared in connection with the '421 patent
`that the videographer just identified.
` Let me start by asking you whether
`you've ever been deposed before?
` A. I have not.
` Q. Okay. So let me make sure then that
`you're familiar with the procedure. Do you
`understand that I'll be asking questions, and
`that your counsel may offer an objection, but
`you're still obligated to answer the question
`over his objection. Do you understand that?
` A. I do.
` Q. Okay.
` A. Except in the case where --
` Q. Unless he instructs you not to
`answer.
` A. Yes.
` Q. Okay. You understand that. So
`fine, I just wanted to make sure that you're
`aware that if counsel poses an objection,
`that's to preserve his rights, and that you
`then answer the question.
`
`Page 8
`
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` OVERZET - 5/7/15
`2
` A. Yes.
`3
` Q. You'll have to answer audibly so
`4
`the -- for the record.
`5
` A. Yes.
`6
` Q. Okay. And if you don't understand
`7 my questions along the way, will you mention
`8
`that to me so we can clarify the record?
`9
` A. Yes.
`10
` Q. Okay. On paragraph 11 of your
`11
`declaration, you say that you have been
`12
`retained by Toshiba; is that correct?
`13
` A. Paragraph 11?
`14
` Q. Yes.
`15
` A. That's correct.
`16
` Q. Now, have you been retained by any
`17
`of the other Petitioners in the IPRs against
`18
`the Zond patents?
`19
` A. Yes.
`20
` Q. Would you identify those Petitioners
`21
`for me?
`22
` A. I need to see my other two
`23
`declarations.
`24
` Q. Okay. I don't have them available.
`25 Why don't you just share with me whatever
`Page 9
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`1
` OVERZET - 5/7/15
`2
`recollection you have.
`3
` A. I honestly do not recall which of
`4
`the companies were primarily involved in which
`5
`of the declarations. My primary contact has
`6
`been with the counsel.
`7
` Q. Let's go that route then. Maybe you
`8
`can identify for me the names of counsel you
`9
`have dealt with, and I can figure it out from
`10
`there.
`11
` A. Okay. Mr. Tennant, David Tennant,
`12 Mr. Rismiller, Rismiller -- Rismiller, Mr. Ho,
`13 Mr. Feldhouse, Mr. Rooney. There was -- I'm
`14
`trying to remember lines in emails, because the
`15
`primary contact has been through email, but
`16
`I've met with those five in person.
`17
` Q. And when did you -- when were you
`18
`first retained?
`19
` A. I'm sorry, I now remember. Mr. Hugh
`20
`and Mr. O'Dell. There may have been others as
`21 well.
`22
` Q. But you specifically recall meeting
`23 with each of the individuals that you just
`24
`listed?
`25
` A. Correct.
`
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` OVERZET - 5/7/15
` Q. Okay. And when did you first begin
`representing Toshiba in this matter?
` A. In the IPRs?
` Q. Yes.
` A. That would have been in March of
`this year for the IPR.
` Q. Okay. You mean just a few months
`ago?
` A. Yes, for the specific purpose of the
`IPR now.
` Q. Okay. So did you have any -- did
`you -- did you have any relationship with them
`prior to March when you began representing them
`on the IPR?
` MR. TENNANT: Objection to the
` extent that your answer calls for
` privileged information. I just caution you
` that you can answer the question to the
` extent you are not revealing any privileged
` communication.
` A. I also had discussions with lawyers
`from Duane Morris as part of some consulting.
`Actually with Duane Morris was not specifically
`consulting. It was a little bit odd. It was
`3 (Pages 6 to 9)
`
`TSG Reporting - Worldwide 877-702-9580
`
`Fujitsu et. al. v. Zond IPR2014-00800
`Page 3 Zond Ex. 2018
`
`

`

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` OVERZET - 5/7/15
`an agreement through my university to -- for
`teaching and for providing information.
` Q. Can you elaborate on that? Can you
`identify the subject matter that this
`consulting related to?
` MR. TENNANT: Again, I'll caution
` the witness. I object to the extent it's
` calling for you to reveal privileged
` communication.
` Also to the extent you have any
` confidentiality agreements in place, you
` may want to be careful how you answer and
` not to violate any confidentiality
` agreements.
` A. I don't wish to violate any
`confidentiality in that.
` Q. Fine, and I'm just exploring
`nonconfidential information. So, for example,
`you said you were consulting with Duane Morris;
`correct?
` A. Uh-huh.
` Q. Do you know whether the matter
`related to any one of the Petitioners -- strike
`that.
`
`Page 12
`
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` OVERZET - 5/7/15
`2
` Can you identify any other party
`3
`that this representation or consulting related
`4
`to?
`5
` A. Could you explain to me what you
`6 mean by "participants"?
`7
` Q. Fair enough. I'm imagining a
`8
`situation where Duane Morris actually
`9
`represents a company, for example, in the
`10
`semiconductor space.
`11
` A. Uh-huh.
`12
` Q. And so I'm trying to get at the
`13
`identity of that company. So when I made
`14
`reference to other parties, that's what I had
`15
`in mind. So can you identify for me any other
`16
`entities to whom this consulting related?
`17
` MR. TENNANT: Same objection.
`18
` A. I don't know that I'm -- I don't
`19
`know that I am allowed to speak about whoever
`20
`the counsel there were representing or not.
`21
`They asked me for help with some technical
`22
`understanding. I provided them with some help
`23
`in technical understanding and face-to-face
`24 meetings.
`25
` Q. Okay. Do you know whether the
`Page 13
`
` OVERZET - 5/7/15
`technical material had any relationship to the
`Zond patents?
` A. I'm not -- yes, I do.
` Q. And is the --
` A. I do know whether it related or not.
` Q. And did it relate to the Zond
`patents?
` A. I'm worried about confidentiality in
`that space.
` Q. Do you know whether the
`representation was related to any -- any
`litigation, any patent litigation?
` MR. TENNANT: Again, I object to
` this line of questioning to the extent your
` questions are calling -- requiring the
` witness to reveal privileged communication
` or any confidential communications subject
` to confidentiality agreements. You can
` answer the question to the extent you do
` not violate any of those two agreements.
` A. I'm going to listen to my counsel.
` Q. So is it your position that whether
`or not the representation related to any patent
`litigation, that that is privileged
`
`1
` OVERZET - 5/7/15
`2
`information?
`3
` MR. TENNANT: Same objection.
`4
` A. Would you please repeat that for me?
`5
` MR. BARKER: Would you read that
`6
` back, please.
`7
` (Record read.)
`8
` MR. TENNANT: Same objection.
`9
` A. I have concerns. I have concern
`10
`regarding that. I'm not a lawyer to know
`11
`precisely where that boundary occurs. I,
`12
`therefore, will listen to my counsel.
`13
` Q. Well, let me take a different
`14
`approach then. Have you ever done any
`15
`consulting work for Toshiba outside the context
`16
`of any IPR litigation?
`17
` MR. TENNANT: Object to the form of
`18
` the question, and also to the extent it's
`19
` requiring the witness to reveal privileged
`20
` communication. I just caution you you can
`21
` answer the question to the extent you don't
`22
` reveal any privileged communication.
`23
` A. I do not recall doing consulting
`24 work for Toshiba outside of this.
`25
` Q. And I'm going back in time
`4 (Pages 10 to 13)
`TSG Reporting - Worldwide 877-702-9580
`
`Fujitsu et. al. v. Zond IPR2014-00800
`Page 4 Zond Ex. 2018
`
`

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` OVERZET - 5/7/15
`throughout your entire career. I'm trying to
`get a sense of whether you have done any
`consulting during the course of your career for
`Toshiba.
` MR. TENNANT: Same objection.
` A. If I turn to my -- to my CV, I've
`listed primary consulting work there that I can
`discuss under employment history, concurrent,
`temporary or visiting appointments,
`consultantships.
` Q. So you're referring to the first
`page of your CV attached as Appendix A to your
`declaration; is that correct?
` A. That's correct.
` Q. And under the heading employment
`history: Concurrent, temporary and visiting
`appointments, consultantships, is that what you
`are referring to?
` A. That is correct.
` Q. So is it your testimony that this is
`a comprehensive list of every -- of all
`consulting work you have ever done in your --
`during your career?
` A. This list does not include the
`
`Page 16
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` OVERZET - 5/7/15
`2
`present work.
`3
` Q. With that exception, are there any
`4
`other consulting projects that you have ever
`5
`had during your career that aren't listed here?
`6
` A. Not that I recall.
`7
` Q. So looking at your employment
`8
`history in the heading above, it looks as if
`9
`you have been a faculty member for the
`10 University of Texas at Dallas for your whole
`11
`career. Did I get that right?
`12
` A. Yes, since -- since my -- obtaining
`13 my Ph.D.
`14
` Q. I understand. Now, in the years
`15
`that you have been a professor at the
`16 University of Texas, have you ever taught any
`17
`classes that involve the design of power
`18
`supplies?
`19
` A. I have taught courses on electronic
`20
`devices that are used in the design of power
`21
`supplies, but not a course that is specifically
`22
`devoted to the design of power supplies.
`23
` Q. Understood. But in the courses in
`24 which you were teaching electronic devices, did
`25
`those courses ever touch on the subject matter
`Page 17
`
` OVERZET - 5/7/15
`of power supply design?
` MR. TENNANT: Objection, form.
` A. Because the electronic device
`courses discuss transistors and the operation
`of transistors, which provide amplification of
`a signal, they have -- they provide the basis
`for a power supply, although the design of a
`power supply today would involve multiple
`transistors, multiple systems.
` Q. Understood. So other than your
`general teaching of transistors, did you teach
`any other material that involved power supply
`design?
` MR. TENNANT: Objection, form.
` A. Mostly the courses that I've taught
`have involved -- have been -- have involved
`teaching about the use of power supplies rather
`than the design of power supplies.
` Q. Okay. And in what context were you
`discussing the use of power supplies?
` A. In a teaching context?
` Q. Let me rephrase that. Not a good
`question. What applications were involved when
`you were discussing the use of power supplies?
`
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` OVERZET - 5/7/15
`2
` MR. TENNANT: Objection, form.
`3
` A. Again, in the -- in the context of
`4
`teaching at the University --
`5
` Q. Yeah, let's start there.
`6
` A. -- of Texas at Dallas?
`7
` Q. So for teaching, you mentioned that
`8
`you addressed the use of power supplies, and
`9
`I'm asking, for what uses?
`10
` A. Got it. In -- in coursework, the
`11
`use of power supplies as applied to
`12
`electromagnetic waves, propagation of
`13
`electromagnetic waves or the generation of
`14
`electromagnetic waves and the use in generating
`15
`plasmas primarily for semiconductor processing
`16
`applications, but also for lighting
`17
`applications in some instances.
`18
` In teaching at the university, not
`19
`in a classroom, but with my graduate students
`20
`in the laboratory and in group meetings, in the
`21
`context of pulsing the power supplies and
`22 making measurements of those pulsed waves. I'm
`23
`sure that are there other contexts, but I'm not
`24
`recalling them at the moment.
`25
` Q. Well, let's focus for a bit on the
`5 (Pages 14 to 17)
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`Page 5 Zond Ex. 2018
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` OVERZET - 5/7/15
`power supplies that were used for plasmas. Can
`you characterize for me generally the types of
`power supplies that you refer to in -- in that
`teaching?
` A. I've taught primarily about radio
`frequency power supplies. Also, to a lesser
`extent about DC power supplies about connecting
`or talking about the use of power supplies, so
`in this case it would be how it is that one
`connects and transfers power from the power
`supply to the plasma.
` Q. Got it. So the RF, does that refer
`to a radio frequency oscillating power supply?
` A. It does.
` Q. Meaning that the output signal is an
`oscillating AC signal; did I get that right?
` A. Yes.
` Q. Okay. Now, the DC power supplies
`that you mentioned -- and again, we're staying
`focused on the uses for plasma that you were
`teaching -- can you describe for me generally
`those DC supplies?
` A. Yes.
` Q. Please do so.
`
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` OVERZET - 5/7/15
`2
` A. Those DC supplies are used in the
`3
`formation of both glow discharges, plasmas and
`4
`arcs.
`5
` Q. And can you characterize for me the
`6
`nature of the outputs of those DC supplies?
`7 What was the output format?
`8
` MR. TENNANT: Objection, form.
`9
` A. For any power supply the output
`10
`is -- is power provided by voltage and current.
`11
` Q. Right.
`12
` A. Is that what you were asking?
`13
` Q. No. You distinguished DC from RF,
`14
`and I'm trying to explore -- get an
`15
`understanding of the distinction between the
`16
`two.
`17
` A. Ah, got it.
`18
` MR. TENNANT: Objection, form.
`19
` A. I think I have it. So you want me
`20
`to describe how I would distinguish between a
`21
`radio frequency power supply and the DC power
`22
`supply; is that --
`23
` Q. Yes, in very general terms.
`24
` A. -- correct?
`25
` Q. And again, at the moment we're
`
`Page 20
`
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`
` OVERZET - 5/7/15
`focused on the teaching that you did in your
`classroom. You mentioned --
` A. Got it.
` Q. -- use of DC power supplies --
` A. Got it.
` Q. -- for use in plasmas, and can you
`explain for us in very general terms the
`difference between the DC outputs and the RF
`outputs in those supplies?
` MR. TENNANT: Objection, form.
` A. Got it. Allow me to remind you that
`I was discussing primarily about the
`application of those supplies and teaching
`about this. DC power supplies require an
`electrical connection to the plasma, whereas
`radio frequency power supplies do not.
` Q. All right. So RF is some kind of
`inductive process?
` A. It can be.
` Q. So other than the direct connection
`to the plasma, can you characterize for me in
`any way the nature of the outputs of the DC
`supplies we are referring to?
` MR. TENNANT: Objection, form.
`
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` A. What do you mean by nature of the
`outputs?
` Q. I'm speaking very generally. All
`you've told me so far is that DC bears a direct
`connection?
` A. Correct.
` Q. And you've also told me that RF has
`an oscillating output. And so I'm trying to
`get a better understanding of the distinction
`between the DC outputs and the RF outputs. Can
`you elaborate on the nature of the distinction
`beyond telling me that DC is directly connected
`to the plasma?
` MR. TENNANT: Objection, form,
` mischaracterizes testimony.
` A. Well, DC is substantially constant
`over a period of time. And when discussing RF,
`I'm generally discussing a power source which
`provides a sinusoidal wave. So DC, that's the
`basic difference.
` Q. Okay. Now, in the courses where you
`were discussing the use of DC power supplies
`for use with plasmas --
` A. Uh-huh.
`
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`2
` Q. -- was there any lab work where you
`3
`actually used DC supplies?
`4
` MR. TENNANT: Objection, form.
`5
` A. In some instances, yes.
`6
` Q. Okay. Do you remember, you know,
`7
`the manufacturer of those DC supplies?
`8
` A. I cannot envision the name of the
`9 manufacturer of the DC supplies. I own at the
`10
`university, so really the university owns, but
`11
`for my use, several.
`12
` Q. Well, I don't want to go too far
`13
`afield because I'm just trying to get some
`14
`background on your experience in this space.
`15
`So if you'd indulge me for a little longer, can
`16
`you just identify for me what you can recall
`17
`about the -- you know, the models of power
`18
`supplies in your lab right now that you are
`19
`familiar with?
`20
` MR. TENNANT: Objection, form.
`21
` A. Without specifying which is DC and
`22 which might be radio frequency, I can tell you
`23
`that I have power supplies from E&I, Advanced
`24
`Energy, Dressler. I forget the name of at
`25
`least three. I think -- well, I don't want to
`Page 24
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` OVERZET - 5/7/15
`speculate on --
` Q. Yeah, but that's a help. So you've
`got at least these three power supplies in your
`lab that you've used and are familiar with; is
`that correct?
` A. Yes.
` Q. And just quickly before we hop
`ahead, so of the three you mentioned, can you
`identify which is of the RF type and which is
`of the DC type?
` MR. TENNANT: Objection, form.
` A. The Dressler is of the RF type. The
`E&I is a power amplifier. I do not remember
`the name of the manufacturer for my magnetron
`sputtering system, power supply.
` Q. So that's separate from the three
`you just mentioned, the --
` A. It might be.
` Q. Right. Because you also mentioned
`the Advanced Energy power supply. Do you
`remember whether that was a DF -- I'm sorry, an
`RF or a DC?
` A. No, and I may have multiple.
` Q. Okay. Then --
`
`Page 25
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`2
` A. And actually I'm borrowing one at
`3
`the moment from another company for research
`4 work, but since that's ongoing research work, I
`5
`cannot talk about that.
`6
` Q. No, fair enough, and I'm just trying
`7
`to get very general background information on
`8
`your experience and exposure to power supplies,
`9
`so we don't need to go there, I don't think.
`10 Well, let's talk about the magnetron sputtering
`11
`system you have. What type of power supply
`12
`does that have in it?
`13
` A. It has a DC with an add-on that
`14
`allows it to be a pulsed DC.
`15
` Q. Can you elaborate on that a little
`16
`bit? What do you mean by this add-on?
`17
` A. It has been too long for me to
`18
`remember the details of this, and we primarily
`19
`used the DC supply and not that add-on.
`20
` Q. Okay. Do you know who -- who
`21 manufactured the add-on that you are referring
`22
`to?
`23
` A. I cannot remember.
`24
` Q. When was the last time that you used
`25
`the add-on?
`
`1
` OVERZET - 5/7/15
`2
` MR. TENNANT: Objection, relevance.
`3
` A. It was a long time ago.
`4
` Q. Can we ball-park it? A year, are we
`5
`talking a year, five years?
`6
` A. Greater than one year.
`7
` Q. Greater than one year. All right.
`8 Well, so far we have been exploring your
`9
`teaching of -- the relationship between your
`10
`teaching and power supply design and the lab
`11 work. Let me more generally explore your
`12
`experience with power supplies for use in
`13
`plasma systems.
`14
` A. Uh-huh.
`15
` Q. Can you give me an overview, a
`16
`generalized summary of your experience in that
`17
`area?
`18
` MR. TENNANT: Objection, form.
`19
` A. Can you -- could you make that
`20
`question a little bit more specific for me?
`21
` Q. Sure, I'll try, but it is a general
`22
`question by nature, and basically aside from
`23
`your coursework, which we just explored --
`24
` A. Right.
`25
` Q. -- I want to explore any additional
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`2
`experience you have with the use of power
`3
`supplies for generating plasmas.
`4
` A. Okay.
`5
` MR. TENNANT: Objection, form.
`6
` A. Okay. In graduate school I began
`7
`studying plasma science and used radio
`8
`frequency power supplies for generating those
`9
`plasmas. Those plasmas were pulsed plasmas, in
`10
`the 1980s I'm talking about.
`11
` Since that time, I have studied the
`12
`use of power supplies to generate pulsed
`13
`plasmas, specifically focusing on diagnosing
`14
`the generation and the recombination of the
`15
`plasmas looking at how it is that plasmas turn
`16
`on and turn off.
`17
` I've been awarded an AVS fellow --
`18
`as an AVS fellow for that work specifically
`19
`related to looking at how negative ions emerge
`20
`from plasmas and turn off. I've also looked at
`21
`the use of pulsed -- what I would call pulsed
`22 DC power supplies for extracting negative ions
`23
`from pulsed plasmas. I think that gives an
`24
`overview.
`25
` Q. No, that's -- thank you. A few
`
`Page 28
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`1
` OVERZET - 5/7/15
`2
`things I want to follow up on to make sure I
`3
`understand. You mentioned plasmas turning on
`4
`and turning off. Can you explain what you mean
`5
`by that?
`6
` MR. TENNANT: Objection, form.
`7
` A. I mean looking at the ignition of a
`8
`plasma in time to understand how that ignition
`9
`occurs and how it is that various species are
`10
`generated in time at the ignition and looking
`11
`at what happens when the power is either turned
`12
`off or reduced. And by the way, if it's
`13
`reduced, then the next turn on would be from
`14
`non-zero power.
`15
` Q. Okay. So did I understand you
`16
`correctly that turning on a plasma refers to --
`17
`you are referring to ignition of a plasma; is
`18
`that right?
`19
` A. No.
`20
` Q. Oh, okay. So then we should explore
`21
`this a bit more, okay. So I asked you to
`22
`explain the difference between -- or what you
`23 mean by turning on and turning off a plasma,
`24
`and you mentioned ignition. Can you explain
`25
`for me the relationship between ignition of a
`Page 29
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`2
`plasma and the terms, quote, turn on and,
`3
`closed quote, turn off?
`4
` MR. TENNANT: Objection, form.
`5
` A. So ignition of the plasma is an
`6
`event where the plasma is going from a
`7
`substantially nearly zero set of ions and
`8
`electrons present to a larger set of ions and
`9
`electrons present. This is the idea of
`10
`ignition.
`11
` Q. Okay.
`12
` A. Turning on the plasma can involve
`13
`increasing those -- can involve going from a
`14 much, much smaller -- actually in the context
`15
`of my research, turning on that -- the plasma
`16
`has generally related to igniting the plasma.
`17
` Q. Okay.
`18
` A. So I should amend that.
`19
` Q. That's fine. And so I think I know
`20 what you mean by turning off the plasma, but
`21
`let me just ask to be clear. So can you
`22
`describe for me what you mean by turning off
`23
`the plasma?
`24
` A. Yeah. What I describe turning off
`25
`the plasma, I generally mean turning the power
`
`1
` OVERZET - 5/7/15
`2
`to zero such that the plasma recombines.
`3
` Q. So the first part of that dealt with
`4
`the power supply; correct? You said turning
`5
`off the power?
`6
` A. Uh-huh, or reducing the voltage to
`7
`zero.
`8
` Q. Okay.
`9
` A. Well, not to zero. To a low value.
`10
` Q. So let's focus on the condition of
`11
`the plasma that you have in mind when you say
`12
`"turn off." So you turn off the power.
`13
` A. Uh-huh.
`14
` Q. What happens?
`15
` MR. TENNANT: Objection, form.
`16
` A. How detailed of an answer do you
`17 want?
`18
` Q. General. I agree, you could
`19
`probably talk for a while about it. I'm just
`20
`trying to get a big picture overview.
`21
` A. Got it.
`22
` MR. TENNANT: Objection, form.
`23
` Q. So same question, just with that --
`24 with that guidance.
`25
` MR. TENNANT: Same objection.
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`2
` A. Got it. So when you greatly reduce
`3
`the power, the voltage, ions and electrons will
`4
`recombine and the -- as a result, the ion
`5
`density, the electron density will reduce.
`6
` Q. Right, so --
`7
` A. Does that answer the question?
`8
` Q. It does, actually. That was very
`9
`helpful. I'm assuming then, and correct me if
`10
`I'm wrong, that when the combination is such
`11
`that the ion and electron density reduces to
`12
`zero, is that the event that corresponds to
`13 what you call turning off the plasma?
`14
` MR. TENNANT: Objection, form.
`15
` A. The ion and electron densities
`16
`rarely reduce to zero.
`17
` Q. Even in the absence of any power
`18
`from the power supply?
`19
` A. In the air around us now, there are
`20
`non-zero numbers of ions and electrons.
`21
` Q. Okay.
`22
` A. There is no power supply I assume on
`23
`this room.
`24
` Q. Right. But we -- we agree there's
`25
`no plasma floating among us, so -- or do we
`Page 32
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` OVERZET - 5/7/15
`even disagree on that?
` MR. TENNANT: Objection, form.
` A. In this case we would agree that the
`plasma would be defined to be -- to not be
`existent, but there would still be some ions
`and some electrons present in the room, and
`likewise, when the power is reduced, there are
`still some ions and electrons that remain.
` Q. Okay. In ambient conditions with no
`external electric field, you're saying that
`there are ions and electrons that are in
`existence all the time?
` MR. TENNANT: Objection, form.
` A. Yes.
` Q. Okay. I want to ask you now to
`clarify another part of your earlier testimony.
`You mentioned in grad school using an RF plasma
`source to create a pulsed plasma?
` A. Yes.
` Q. Can you explain -- can you elaborate
`on what you mean by "pulsed plasma" in that
`context?
` A. In that context --
` Q. Yes.
`
`Page 33
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` OVERZET - 5/7/15
` A. -- as evidenced in my publication --
`I'm sorry. Number 77 and number 76, it would
`be under the topic "Articles in Refereed
`Journals."
` MR. TENNANT: What page of the CV
` are you on, for the record?
` THE WITNESS: My CV doesn't have
` pages, in the version that I have anyway,
` but if you go --
` Q. Let me hand you a copy, then, of
`the --
` A. If you go --
` Q. Let me hand you a copy of the
`declaration that you submitted in IPRs numbers
`2014-00800, 00802, 00805. And I think the CV
`you have on the back of that may have some page
`numbers that will help us. And in particular,
`I've opened up to page 14 of your CV, and
`there's a 75 and 70 -- I'm sorry, 76 and 77
`there. Is that what you're referring to?
` A. Let me -- no. This is the page that
`you were looking at?
` Q. Number 76, "Stability of
`nanostructured" --
`
`