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`Page 1
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD.
`AND TSMC NORTH AMERICA CORP., Case Nos.
` IPR2014-00800
` Petitioners, IPR2014-00802
` IPR2014-00805
`-vs-
`ZOND, LLC,
` Patent Owner.
`________________________________
`
` VIDEOTAPED DEPOSITION of DR. UWE KORTSHAGEN
` Minneapolis, Minnesota
` December 23rd, 2014
`
`Reported by:
`Amy L. Larson, RPR
`Job No. 88563
`
`TSG Reporting - Worldwide
`(877) 702-9580
`
`TSMC et. at. v. Zond, IPR2014-00805
`Page 1 Exhibit 2017
`
`

`

`Page 2
`
`Page 3
`
`APPEARANCES: (CONT'D.)
` WHITE & CASE
` 701 Thirteenth Street NW
` Washington, D.C. 20005
` By: David Tennant, Esq.
` For: Global Foundries
`
` WHITE & CASE
` 3000 El Camino Real
` 5 Palo Alto Square
` Palo Alto, California 94306
` By: Brett Rismiller, Esq.
` For: Global Foundries
`
` BAKER BOTTS
` One Shell Plaza
` 910 Louisiana Street
` Houston, Texas 77002
` By: Robinson Vu, Esq. (via telephone)
` For: Toshiba
`
` ALSO PRESENT: Adam Wallin, Videographer
`
`Page 5
`
` DR. UWE KORTSHAGEN
`THE VIDEOTAPED DEPOSITION OF DR. UWE KORTSHAGEN,
`taken on this 23rd day of December, 2014, at The
`Commons Hotel, 615 Washington Avenue, S.E.,
`Minneapolis, Minnesota, commencing at
`approximately 8:02 a.m.
` P R O C E E D I N G S
` THE VIDEOGRAPHER: We are on the
` record. This is the videotaped deposition of
` Dr. Uwe Kortshagen in the matter of Taiwan
` Semiconductor Manufacturing Company Limited,
` et al., vs. Zond, LLC, in the United States
` Patent and Trademark Office before the
` Patent Trial and Appeal Board, IPR2014-00800,
` IPR2014-00802, IPR 2014-00805.
` This deposition is being held at The
` Commons Hotel in Minneapolis, Minnesota.
` Today's date is December 23rd, 2014. The
` time is approximately 8:04 a.m.
` My name is Adam Wallin, I'm the legal
` video specialist from TSG Reporting,
` Incorporated, headquartered at 747 Third
` Avenue, New York, New York. The court
` reporter is Amy Larson in association with
` TSG Reporting.
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`APPEARANCES:
` RADULESCU
` 350 Fifth Avenue
` New York, NY 10118
` By: Maria Granovsky, Ph.D., Esq.
` For: Zond, LLC
`
` CHAO HADIDI STARK & BARKER
` 176 East Main Street
` Westborough, MA 01581
` By: Bruce Barker, Esq.
` For: Zond, LLC
`
` DUANE MORRIS
` 100 High Street
` Boston, MA 02110
` By: Anthony Fitzpatrick, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
` HAYNES AND BOONE
` 2323 Victory Avenue
` Dallas, Texas 75219
` By: David McCombs, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
` HAYNES AND BOONE
` 2505 North Plano Road
` Richardson, Texas 75082
` By: Gregory Huh, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
`Page 4
`
`INDEX:
`EXAMINATION BY: PAGE
`Ms. Granovsky...............................8
`EXHIBITS MARKED FOR IDENTIFICATION:
`Exhibit 1...................................9
`U.S. Patent 7,811,421 B2
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`

`

`Page 6
`
` DR. UWE KORTSHAGEN
` Will counsel please identify themselves
`for the record.
` MS. GRANOVSKY: Maria Granovsky
`from Radulescu, LLP, for patent owner
`Zond, LLC.
` MR. FITZPATRICK: Anthony
`Fitzpatrick from Duane, Morris, LLP on behalf
`of Taiwan Semiconductor Manufacturing Company
`Limited and TSMC North America.
` MR. TENNANT: David Tennant from
`White & Case for Global Foundries Dresden
`Module One LLC & and Co. KG, Global Foundries
`Dresden Module Two LLC & Co. KG, and Global
`Foundries U.S., Inc.
` MR. MCCOMBS: David McCombs with
`Haynes & Boone for TSMC, TSMC North America
`and Fujitsu.
` MR. HUH: Gregory Huh with
`Haynes & Boone for TSMC, TSMC North America
`and Fujitsu.
` MR. RISMILLER: Brett Rismiller
`with White & Case, LLP, for Global Foundries.
` THE VIDEOGRAPHER: Will the court
`reporter please swear in the witness.
`
`Page 8
`
` DR. UWE KORTSHAGEN
` on the record.
` EXAMINATION
`BY MS. GRANOVSKY:
`Q. Good morning, Dr. Kortshagen.
`A. Good morning, Dr. Granovsky.
`Q. You understand that you have just taken an
` oath to testify truthfully?
`A. I do.
`Q. And is there any reason why you cannot
` testify truthfully?
`A. There is no reason.
`Q. Is there any medication that you're taking
` that will prevent you from testifying
` truthfully?
`A. No.
`Q. Okay. I handed you a document previously
` marked as TSMC 1002, and I'll represent to
` you that this is from IPR Number 2014-00800.
` Do you recognize this document?
`A. I do.
`Q. What is it?
`A. It is my declaration regarding claims 1, 2,
` 8, 10 through 13, 15 through 17, 22 through
` 25, 27 through 30, 33, 34, 38, 39, 42, 43
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`Page 7
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` DR. UWE KORTSHAGEN
` MR. FITZPATRICK: Do we have
`anybody on the phone?
` MR. BARKER: Before we start, as
`we took the role call -- this is Bruce
`Barker -- the only one I could really hear
`well was Dave McCombs, so I don't know where
`the microphone is placed, but if you could --
`so that I don't interrupt, before we start if
`you could place it closer to the witness,
`that would be helpful.
` MR. VU: Also, this is Robinson Vu
`with Baker, Botts for Toshiba.
`
` DR. UWE KORTSHAGEN,
` a witness in the above-entitled action,
` after having been first duly sworn, was
` deposed and says as follows:
` MR. FITZPATRICK: Before we begin,
`I just want to state on the record that
`objections made to questions apply to all
`petitioners so that we avoid duplicate
`objections. We've been doing that throughout
`the depositions, and I believe it's
`understood, but I just wanted to confirm it.
`
`Page 9
`
` DR. UWE KORTSHAGEN
` and 46 through 48 of Patent 7,811,421.
`Q. Okay.
` (Whereupon, Exhibit 1 was
` marked for identification.)
`BY MS. GRANOVSKY:
`Q. And the court reporter just handed you a
` document marked Exhibit 1. Do you recognize
` this document?
`A. I do.
`Q. What is it?
`A. It is the Patent 7,811,421.
`Q. Okay. And you have reviewed this document
` before?
`A. I have reviewed this document, yes.
`Q. Okay. And before we begin, actually, what
` have you done to prepare for this deposition?
`A. For this deposition I prepared over the
` weekend, and I -- I think I spent maybe half
` an hour to an hour yesterday evening looking
` at some documents again. That is pretty much
` what I've done.
`Q. Did you speak to counsel yesterday as well or
` did you just look at the documents?
`A. We did have -- got together for breakfast
`
`TSG Reporting - Worldwide
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`Page 10
` DR. UWE KORTSHAGEN
` this morning. We did have some discussions
` about the deposition today.
`Q. Okay. So if you turn in your declaration to
` page 11.
`A. Yes.
`Q. To the section that says, quote, "Overview of
` the '421 patent."
`A. Yes.
`Q. It says that, "The claims of the '421 patent
` are directed to using a single voltage pulse
` to generate a so-called weakly ionized plasma
` and then a strongly ionized plasma in a
` manner that avoids arcing"; is that correct?
`A. That is correct.
`Q. What is your understanding of a single
` voltage pulse?
`A. My understanding of a single voltage pulse is
` a pulse that can have a certain waveform, for
` instance, going from a lower voltage to a
` higher voltage and then decreasing to a lower
` level again.
`Q. And is it your understanding that that single
` voltage pulse has to generate both a weakly
` ionized plasma and then a strongly ionized
`
`Page 12
` DR. UWE KORTSHAGEN
` form.
` THE WITNESS: Yeah. I mean, if
` I -- I consider a pulse to be a pulse which
` goes from a low -- let's say a low level of
` voltage to a high level of voltage, and this
` pulse maintains a weakly ionized plasma at
` the low level of voltage and then creates a
` strongly ionized plasma at the high level of
` voltage, I would say this is the same pulse
` doing this.
`BY MS. GRANOVSKY:
`Q. What is your interpretation of creating a
` weakly ionized plasma?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: Creating a weakly
` ionized plasma? So if we talk about the
` creation of a plasma, I would assume that we
` talk about the mechanism, which is typically
` referred to as ignition of the plasma where
` you go from a state where you do not have a
` plasma present to a state where you now have
` a plasma present.
` MS. GRANOVSKY: Okay.
`
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`Page 11
` DR. UWE KORTSHAGEN
` plasma from the weakly ionized plasma,
` according to this invention?
` MR. FITZPATRICK: Object to the
` form of the question.
` THE WITNESS: So this is in
` paragraph 29, a summary statement which was
` made. I'm not sure that this statement is
` applicable to each of the individual claims
` that I expect we will be discussing. So from
` that point of view, I would not overinterpret
` this summary statement, but would prefer, if
` we want to discuss the action of the voltage
` pulse creating weakly and strongly ionized
` plasma, and whether this is a single pulse,
` if we discuss that with respect to particular
` claims.
`Q. And we will do that, but --
`A. Yeah.
`Q. -- my question is, in general, if -- if a
` statement says a single pulse to generate a
` weakly ionized plasma and then a strongly
` ionized plasma, do you expect the same pulse
` to have to do both?
` MR. FITZPATRICK: Object to the
`
`Page 13
`
` DR. UWE KORTSHAGEN
`BY MS. GRANOVSKY:
`Q. Let's turn to claim 1 of the '421 patent.
`A. Yes.
`Q. Subpart B of the claim --
`A. Yes.
`Q. -- reads, "A power supply that generates a
` voltage pulse between the anode and the
` cathode assembly that creates a weakly
` ionized plasma and then a strongly ionized
` plasma from the weakly ionized plasma without
` an occurrence of arcing between the anode and
` the cathode assembly, an amplitude, a
` duration and a rise time of the voltage pulse
` being chosen to increase a density of ions in
` the strongly ionized plasma"; is that
` correct?
`A. That is correct, yes.
`Q. Is it your understanding that this claim
` limitation requires the same voltage pulse to
` create both a weakly ionized plasma and then
` a strongly ionized plasma from the weakly
` ionized plasma?
`A. Yeah, it is my understanding that this claim
` limitation talks about a voltage pulse which
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`Page 14
` DR. UWE KORTSHAGEN
` creates a weakly ionized plasma and then
` creates -- so following the creation of a
` weakly ionized plasma, then creates a
` strongly ionized plasma from the weakly
` ionized plasma, yes.
`Q. And it is the same pulse that creates both,
` right?
`A. That is what the claim language seems to
` imply, yes.
`Q. Okay. Is it your understanding that this
` claim element requires that both the creation
` of a weakly ionized plasma and then a
` strongly ionized plasma from the weakly
` ionized plasma occurs without arcing?
` MR. FITZPATRICK: I object to the
` form of the question.
` THE WITNESS: Could you repeat the
` question, please?
` MS. GRANOVSKY: Sure.
`BY MS. GRANOVSKY:
`Q. Is it your understanding that this claim
` element requires that both the creation of a
` weakly ionized plasma and then a strongly
` ionized plasma from the weakly ionized
`
`Page 16
` DR. UWE KORTSHAGEN
` plasma and the end?
`A. Is there a comma? No.
`Q. Is there a comma -- strike that.
` Is it possible to interpret the claim as
` referring to both -- as without the --
` without an occurrence of arcing referring to
` both the creation of the weakly ionized
` plasma and then a strongly ionized plasma
` from the weakly ionized plasma?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: Is it possible to
` interpret it like this? I -- I think we're
` getting into the realm of legal
` interpretation, which is not my strength. I
` think I was asked to be here for my technical
` expertise.
` But from my -- my plain reading of the
` claim language and from my understanding,
` when a pulse plasma is the highest
` probability of arcing occurs, namely, during
` the creation of the strongly ionized plasma,
` from my plain reading of the language it
` would be that the -- without occurrence of an
` arc or without occurrence of arcing, applies
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`Page 15
`
` DR. UWE KORTSHAGEN
` plasma occurs without arcing?
`A. Aha.
` MR. FITZPATRICK: Same objection.
` THE WITNESS: So you said that
` both the weakly ionized plasma -- the
` creation of the weakly ionized plasma and the
` strongly ionized plasma from the weakly
` ionized plasma occurs without arcing?
` MS. GRANOVSKY: Yes.
` THE WITNESS: You used the word
` both. I see. So if I read the claim
` language, it seems to imply that the without
` occurrence of arcing refers to the creation
` of the strongly ionized plasma from the
` weakly ionized plasma, because it says -- it
` talks about a voltage pulse that creates a
` weakly ionized plasma, and it says, "And
` then," so following that creation of the
` weakly ionized plasma it creates a strongly
` ionized plasma from the weakly ionized plasma
` without an occurrence of arcing.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. Is there a comma between weakly ionized
`
`Page 17
` DR. UWE KORTSHAGEN
` to the creation of the strongly ionized
` plasma.
` MS. GRANOVSKY: I was actually
` looking for your plain English
` interpretation, so not the legal definition,
` so that's fine.
` THE WITNESS: Well, I think I gave
` you my plain English interpretation by
` pointing out that the claim talks about the
` creation of a weakly ionized plasma as one
` step, and then as the second step, the
` creation of a strongly ionized plasma from a
` weakly ionized plasma without occurrence of
` arcing. That was my plain English reading of
` what is described here.
`Q. As we discussed before, there is no comma
` between weakly ionized plasma and then a
` strongly ionized plasma; is that correct?
` MR. FITZPATRICK: Objection; asked
` and answered, form.
` THE WITNESS: There is indeed no
` comma, I agree.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
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`Page 18
` DR. UWE KORTSHAGEN
`Q. Is it your understanding that this claim
` limitation requires choosing an amplitude, a
` duration and a rise time of the voltage
` pulse?
` MR. FITZPATRICK: Objection to
` form.
` THE WITNESS: Yes, it does.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. Can you find the Wang reference, please?
`A. Yes, I have it right here.
`Q. And have you reviewed this reference in
` connection with forming an opinion regarding
` the claims of the '421 patent?
`A. I did, yes.
`Q. Okay. If you turn to paragraph 100 in your
` declaration, that's on page 41.
`A. Yes.
`Q. It analyzes the claim limitation that creates
` a weakly ionized plasma and then a strongly
` ionized plasma from the weakly ionized
` plasma; is that correct?
`A. That is correct, yes.
`Q. And this claim limitation describes the
`
`Page 20
`
` DR. UWE KORTSHAGEN
` discloses such a voltage pulse, as explained
` in paragraphs 100 and 101 of my declaration.
`Q. Okay. Without reading them verbatim, can you
` paraphrase what -- what your opinion is how
` Wang discloses it?
`A. Yes.
` MR. FITZPATRICK: I just note
` objection to the form.
` Go ahead.
` THE WITNESS: Okay. So it's my
` understanding that Wang discloses a voltage
` pulse that creates a weakly ionized plasma by
` applying a background power, P sub B, and
` then a strongly ionized plasma from that
` weakly ionized plasma by applying a power
` P sub P.
` Is this -- is that the answer you were
` looking for?
` MS. GRANOVSKY: It's your answer.
` THE WITNESS: Okay, okay.
` MS. GRANOVSKY: If this is your
` answer, yes.
`BY MS. GRANOVSKY:
`Q. So you say that Wang discloses a voltage
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`Page 19
` DR. UWE KORTSHAGEN
` previous phrase in the claim element, which
` is, "A voltage pulse between the anode and
` the cathode assembly"; is that correct?
` MR. FITZPATRICK: I object to the
` form of the question.
` THE WITNESS: Yes, that is
` correct.
`BY MS. GRANOVSKY:
`Q. So this claim element can be read as a
` voltage pulse that creates a weakly ionized
` plasma and then a strongly ionized plasma
` from the weakly ionized plasma; is that
` correct?
` MR. FITZPATRICK: Object to the
` form of the question.
` THE WITNESS: Yes. I think you're
` correct, yes.
`BY MS. GRANOVSKY:
`Q. Is it your opinion that Wang discloses a
` single voltage pulse that both creates a
` weakly ionized plasma and then a strongly
` ionized plasma from the weakly ionized
` plasma?
`A. Yes, it is my understanding that Wang
`
`Page 21
` DR. UWE KORTSHAGEN
` pulse that creates a weakly ionized plasma
` and then that he applies power P sub P to the
` weakly ionized plasma to create the strongly
` ionized plasma; is that correct?
` MR. FITZPATRICK: Object to form.
`BY MS. GRANOVSKY:
`Q. Shall I repeat --
`A. Could you reread your question, then I can
` tell you whether I agree?
`Q. So if I understand you correctly, you say
` that Wang discloses a voltage pulse that
` creates a weakly ionized plasma, and then
` that he applies power P sub P to the weakly
` ionized plasma to create the strongly ionized
` plasma; is that correct?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: Yes. I think that
` is correct, yes.
`BY MS. GRANOVSKY:
`Q. And in your opinion, the pulse that creates
` the plasma and the application of the power
` P sub P is part of the same pulse?
`A. Excuse me, Dr. Granovsky, I know it's very
` difficult with your computer, could you
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` DR. UWE KORTSHAGEN
` turn a little bit more towards me, then it
` would be easier for me to understand you.
`Q. I'm sorry.
`A. I know it's very hard to do that for you.
`Q. And in your opinion, the pulse that creates
` the plasma and the application of the power
` P sub P to the weakly ionized plasma is part
` of the same pulse?
`A. Could you -- excuse me, please reread the
` question. In my opinion --
`Q. In your opinion, the pulse that creates the
` plasma and the application of the power
` P sub P to the weakly ionized plasma is part
` of the same pulse?
`A. Just to be sure, can you -- can you specify?
` You say the pulse that creates the plasma, so
` we're talking about which plasma?
`Q. The weakly ionized plasma.
`A. The weakly ionized plasma. So the pulse that
` creates the weakly ionized plasma and then
` applies P sub P to that weakly ionized
` plasma, whether that is the same pulse?
`Q. Yes.
`A. I think this is within the framework of
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` DR. UWE KORTSHAGEN
` frequency is named Tau P here that is -- I
` don't know how Wang specifically calls it. I
` think it's the pulse period, so meaning the
` time in between pulses.
` And so if we look at Figure 6, if Tau P
` is the period between pulses, then that would
` suggest a definition of the pulse as a wave
` -- part of this waveform, which includes the
` background power, P sub B, and the peak
` power, P sub P.
`BY MS. GRANOVSKY:
`Q. But isn't the pulse width actually defined as
` Tau sub W?
`A. Again, that, I think, depends on how you
` interpret that. We could also call it Tau
` sub -- Tau sub W the pulse width of the peak
` power portion of the overall pulse.
`Q. And is it your understanding -- so your
` understanding is, just so we're clear, that
` this is actually a power pulse, right?
`A. What Figure 6 shows is the power, the
` idealized power of the sequence of electrical
` pulses. So one could now equally draw a
` figure of voltage pulses or current pulses,
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` DR. UWE KORTSHAGEN
` this patent, the definition that we have
` adopted, that there is a pulse which includes
` a low power background power, part P sub B,
` and then a high power, peak power, part P sub
` P, yes.
`Q. What is your basis for characterizing the
` background power as a pulse?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: If we go to Wang's
` patent, Figure 6, so I think we discussed
` this yesterday, and I think I mentioned at
` that time that the definition of what is the
` pulse may be a little bit arbitrary, and in a
` sense, semantics whether one says there is a
` background power to which pulses are applied
` or whether there is a pulse which includes
` both the background power part and the peak
` power part. But if we look at Figure 6, I
` think it is very suggestive of assuming that
` it shows a sequence of pulses and the
` sequence of pulses appears with a certain
` frequency. And if we look at Figure 6, that
` frequency, or better, the in verse of the
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` DR. UWE KORTSHAGEN
` because power, current and voltage are
` connected with each other.
`Q. So a person of skill in the art could draw
` the voltage pulse associated with this power
` pulse?
`A. I think so.
`Q. And a person of skill in the art could derive
` the rise time, the amplitude and the duration
` of the voltage pulse from this diagram?
`A. From Figure 6?
`Q. Yes.
`A. Let me see what we need. (Reviews document.)
` I think a person of skill in the art
` could certainly derive the duration from
` these pulses, because the duration is simply
` given by the pulse period, Tau P, or if we
` wanted to talk about duration as the duration
` of the peak power part of the pulse, it would
` be given by Tau W, Tau sub W.
` Because this is an idealized waveform, I
` believe it would be hard from this idealized
` waveform to read a rise time, so it would be
` difficult to do this from Figure 6.
` And the amplitude, yeah, again, this
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` DR. UWE KORTSHAGEN
` is idealized, because it is the specification
` of Wang actually specifies that the
` difference in power is ideally a factor of
` 1,000, which is not really represented here.
` So from Figure 6 it would be difficult to
` find an amplitude.
`Q. But it is your opinion that from the
` disclosure of Wang, it would be possible to
` find the amplitude of the voltage pulse?
`A. Well, Wang discloses a power, not a voltage,
` but so Wang does not specifically disclose a
` value for the amplitude of the voltage.
`Q. Okay.
`A. I think it discloses a voltage pulse. It
` does not specifically disclose the value of
` the voltage.
`Q. Okay. Now, getting back to the issue of what
` those square pegs on Figure 6 represent, if
` you look at column 5, line 42 --
`A. Of Wang?
`Q. Of Wang.
`A. Of Wang?
`Q. Uh-huh. And it says, "The choice of pulse
` width Tau W is dictated by considerations,"
`
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` DR. UWE KORTSHAGEN
` from the weakly ionized plasma?
` MR. TENNANT: Objection to form.
` THE WITNESS: Could you repeat the
` question, please?
` MS. GRANOVSKY: Sure.
`BY MS. GRANOVSKY:
`Q. So if we concede that the pulse is actually
` described by the width Tau W, does Figure 6,
` in your opinion, disclose a single voltage
` pulse that both creates a weakly ionized
` plasma and then a strongly ionized plasma
` from the weakly ionized plasma?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: I think if someone
` just hands me Figure 6 and asks me whether
` this figure shows a train of pulses which
` create a weakly ionized plasma and then a
` strongly ionized plasma from a weakly ionized
` plasma, then I would say yes, it does
` disclose that.
`BY MS. GRANOVSKY:
`Q. That's not exactly what I asked. What I
` asked was: Does it describe a single pulse
` that creates both a weakly ionized plasma
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` DR. UWE KORTSHAGEN
` et cetera, correct?
`A. Correct.
`Q. So it doesn't describe Tau W as the peak
` power portion of the pulse; is that correct?
`A. Wang does not specifically use these words,
` that is correct.
`Q. In fact, nowhere Wang does he describe Tau W
` as the peak portion of the pulse --
`A. Aha.
`Q. -- is that correct?
`A. Well, if you're asking me that it in where in
` Wang describes this as the peak portion of
` the pulse, then at this point I cannot tell
` you that, because I really had to reread the
` patent to be sure that it nowhere describes
` it as that.
`Q. But as of right now, you can't recall --
`A. As of right now, I cannot recall that it
` would call it, that's right, yeah.
`Q. So if we concede that the pulse is actually
` described by that width Tau W, does Figure 6,
` in your opinion, disclose a single voltage
` pulse that both creates a weakly ionized
` plasma and then a strongly ionized plasma
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` DR. UWE KORTSHAGEN
` and then a strongly ionized plasma from a
` weakly ionized plasma?
` MR. FITZPATRICK: Object to form,
` asked and answered.
` THE WITNESS: So Figure 6 does not
` disclose a single pulse, it discloses a
` train, a sequence of five pulses.
`BY MS. GRANOVSKY:
`Q. Let me try to get it from a different
` position.
` If the pulse is defined by its width as
` Tau W --
`A. Uh-huh.
`Q. -- does it disclose the creation of a weakly
` ionized plasma?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: So you're asking
` whether if -- if the pulse were only to be
` defined by Tau W, whether in that case the
` pulse would describe the creation of a weakly
` ionized plasma; is that correct?
` MS. GRANOVSKY: Yes.
` THE WITNESS: So I'll be happy to
` answer that question, even though I don't
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` DR. UWE KORTSHAGEN
` share the opinion that the pulse should
` necessarily be defined as consisting only of
` the piece that is labeled with the width
` Tau W here.
` But I think one of ordinary skill would
` understand that even if we were to adopt this
` definition, which I do not share, at the
` beginning of this pulse, there would be a
` weakly ionized plasma.
`BY MS. GRANOVSKY:
`Q. Does it --
` THE WITNESS: Which then
` transitions to a strongly ionized plasma.
` MS. GRANOVSKY: Okay. That's not
` quite what I asked, and I apologize that I
` will have to ask it again.
`BY MS. GRANOVSKY:
`Q. If the pulse is defined by its width as
` Tau W, does -- does this pulse include in it
` the creation of a weakly ionized plasma?
`A. Ah.
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: Yeah, and again,
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` DR. UWE KORTSHAGEN
` THE WITNESS: That is correct,
` yes.
`BY MS. GRANOVSKY:
`Q. So Figure 6 does not depict the event that
` creates the plasma; is that correct?
` MR. FITZPATRICK: Objection to the
` form.
` THE WITNESS: Actually, Figure 6,
` I think -- Figure 6 does not explicitly
` disclose the creation of the plasma. I think
` we added that in the annotated version of
` Figure 6, which in the declaration before me
` can be found on page 16.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. But as Figure 6 is depicted in Wang without
` your annotation, it does not depict a single
` pulse that both creates a weakly ionized
` plasma and then a strongly ionized plasma
` from the weakly ionized plasma; is that
` correct?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: So I think this --
` the creation of the plasma is disclosed in
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` DR. UWE KORTSHAGEN
` don't share your opinion of what constitutes
` the pulse, but if we were only to look at the
` part which is the peak power part with the
` width Tau W, that would not include the
` creation of the weakly ionized plasma.
`BY MS. GRANOVSKY:
`Q. Can you identify all the evidence in Wang on
` which you rely to conclude that any portion
` of P sub B is part of the pulse?
`A. So right now as I sit here, I find that the
` most suggestive piece of that definition is
` actually Figure 6 --
`Q. Okay.
`A. -- which does show a sequence of pulses. And
` in my interpretation, these pulses include a
` part of low power P sub B, as described in my
` declaration, which is then followed by a part
` of peak