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`Page 1
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`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.
` IPR2014-08087
` Petitioners, IPR2014-01099
` IPR2014-00808
`-vs- IPR2014-01100
`ZOND, LLC,
` Patent Owner.
`________________________________
`
` VIDEOTAPED DEPOSITION of DR. UWE KORTSHAGEN
` Minneapolis, Minnesota
` December 22nd, 2014
`
`Reported by:
`Amy L. Larson, RPR
`Job No. 88560
`
`TSG Reporting - Worldwide 877-702-9580
`
`TSMC et al. v. Zond
`IPR2014-00808 Zond Ex. 2007
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`Page 1
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`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.
` IPR2014-08087
` Petitioners, IPR2014-01099
` IPR2014-00808
`-vs- IPR2014-01100
`ZOND, LLC,
` Patent Owner.
`________________________________
`
` VIDEOTAPED DEPOSITION of DR. UWE KORTSHAGEN
` Minneapolis, Minnesota
` December 22nd, 2014
`
`Reported by:
`Amy L. Larson, RPR
`Job No. 88560
`
`TSG Reporting - Worldwide 877-702-9580
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`TSMC et al. v. Zond
`IPR2014-00808 Zond Ex. 2007
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`Page 2
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`APPEARANCES:
` RADULESCU
` 350 Fifth Avenue
` New York, NY 10118
` By: Maria Granovsky
` For: Zond, LLC
` -and-
` ASCENDA LAW GROUP
` 84 West Santa Clara Street
` San Jose, CA 95113
` By: Tarek Fahmi
` For: Zond, LLC
`
` DUANE MORRIS
` 100 High Street
` Boston, MA 02110
` By: Anthony Fitzpatrick
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
` -and-
` HAYNES AND BOONE
` 2323 Victory Avenue
` Dallas, TX 75219
` By: David McCombs
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
` -and-
` HAYNES AND BOONE
` 2505 North Plano Road
` Richardson, TX 75082
` By: Gregory Huh
` Company Limited and
` TSMC North America
`
`TSG Reporting - Worldwide 877-702-9580
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`APPEARANCES: (CONT'D.)
` WHITE & CASE
` 701 Thirteenth Street NW
` Washington, D.C. 20005
` By: David Tennant
` For: Global Foundries
` -and-
` WHITE & CASE
` 3000 El Camino Real
` 5 Palo Alto Square
` Palo Alto, CA 94306
` By: Brett Rismiller
` For: Global Foundries
`
` BAKER BOTTS
` One Shell Plaza
` 910 Louisiana Street
` Houston, TX 77002
` By: Robinson Vu (via telephone)
` For: Toshiba
`
` ALSO PRESENT: Adam Wallin, Videographer
`
`TSG Reporting - Worldwide 877-702-9580
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`IPR2014-00808 Zond Ex. 2007
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`Page 4
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`INDEX:
`EXAMINATION BY: PAGE
`Ms. Granovsky...............................7
`EXHIBITS MARKED FOR IDENTIFICATION:
`Exhibit 1..................................10
`U.S. Patent No. 7,604,716 B2
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`THE VIDEOTAPED DEPOSITION OF DR. UWE KORTSHAGEN,
`taken on this 22nd day of December, 2014, at The
`Commons Hotel, 615 Washington Avenue, S.E.,
`Minneapolis, Minnesota, commencing at
`approximately 9:04 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 taken 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 and Trial Appeal Board,
` Case Number IPR2014-008087 [sic], and also
` IPR2014-01099, and IPR2014-00808, and
` IPR2014-01100.
` This deposition is being held at The
` Commons Hotel in Minneapolis, Minnesota.
` Today's date is December 22nd, 2014. The
` time is approximately 9:05 a.m. My name is
` Adam Wallin, I'm a legal video specialist
` with TSG Reporting Incorporated,
` headquartered at 747 Third Avenue, New York,
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` DR. UWE KORTSHAGEN
`New York. The court reporter is Amy Larson
`in association with TSG Reporting.
` Will counsel please identify themselves
`for the record.
` MS. GRANOVSKY: Maria Granovsky of
`Radulescu, LLP for patent owner Zond, LLC.
` MR. FAHMI: Tarek Fahmi also on
`behalf of Zond.
` MR. FITZPATRICK: Anthony
`Fitzpatrick from Duane, Morris, LLP, on
`behalf of Taiwan Semiconductor Manufacturing
`Company, Limited, and TSMC North America.
` MR. TENNANT: David Tennant of
`White & Case on behalf of Global Foundries
`U.S. Inc., Global Foundries Dresden Module
`One LLC & Co. KG, and Global Foundries
`Dresden Module Two LLC & Co. KG.
` MR. MCCOMBS: David McCombs with
`Haynes & Boone on behalf of TSMC and TSMC
`North America and Fujitsu.
` MR. HUH: Gregory Huh with
`Haynes & Boone on behalf of TSMC, TSMC North
`America and Fujitsu.
` MR. RISMILLER: Brett Rismiller
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` DR. UWE KORTSHAGEN
` with White & Case, LLP, also with
` Global Foundries.
` MR. VU: Robinson Vu with
` Baker, Botts for Toshiba over the phone.
` THE VIDEOGRAPHER: Will the court
` reporter please swear in the witness.
`
` DR. UWE KORTSHAGEN,
` a witness in the above-entitled action,
` after having been first duly sworn, was
` deposed and says as follows:
`
` EXAMINATION
`BY MS. GRANOVSKY:
`Q. Good morning, Dr. Kortshagen.
`A. Good morning.
`Q. Can you please state your full name for the
` record.
`A. My full name is Uwe Richard Kortshagen.
`Q. And can you please spell it?
`A. The first name is U-W-E, middle name
` R-I-C-H-A-R-D, and the last name is
` K-O-R-T-S-H-A-G-E-N.
`Q. I know you've been deposed before, but I'm
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` DR. UWE KORTSHAGEN
` just going to go over the rules again just so
` we're all on the same page. Is that all
` right?
`A. Thank you.
`Q. Do you understand that you've just taken an
` oath to testify truthfully?
`A. I do.
`Q. Do you under -- is there any reason why you
` cannot testify truthfully?
`A. There's no reason.
`Q. Are you taking any medications that might
` impair your ability to testify truthfully?
`A. No.
`Q. And you understand that I'll be asking you
` questions?
`A. Excuse me, please?
`Q. You understand that I will be asking you
` questions?
`A. I do understand that, yes.
`Q. And that you have an obligation to answer my
` questions?
`A. I do.
`Q. And even if your counsel objects, you still
` have to answer my questions?
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` DR. UWE KORTSHAGEN
`A. I do understand.
`Q. Except if he objects for privilege, in which
` case please don't answer the question.
`A. Thank you.
`Q. Okay. If you don't understand a question,
` please ask me to clarify or rephrase it. Is
` that okay?
`A. I will do that. Thank you.
`Q. Because if you answer my question, I will
` assume that you have understood it. Is that
` fair?
`A. That is fair.
`Q. And also make sure to give verbal answers,
` because the court reporter can't record nods
` and head shakes, and uhms and huh-uh are
` difficult.
`A. I understand. Thank you.
`Q. Okay. Did you prepare for today's
` deposition?
`A. I did.
`Q. Okay. What did you do to prepare?
`A. I reviewed the patent, my declarations, the
` Board decisions.
`Q. Okay. Have you met with anyone and
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` DR. UWE KORTSHAGEN
` discussed this matter with anyone in
` preparation?
`A. We had -- I did have a phone discussion with
` my lawyers on Friday.
`Q. Who were the lawyers, do you recall?
`A. The gentlemen who are here at the table. I
` think everyone was on the phone, yes.
`Q. Okay. And how many hours, approximately, did
` you spend preparing for this deposition?
`A. This deposition, I -- I would guess anywhere
` between 10 and 15 hours.
`Q. Okay.
` (Whereupon, Exhibit 1 was
` marked for identification.)
`BY MS. GRANOVSKY:
`Q. The court reporter has just handed you a
` document marked Exhibit 1. This is
` U.S. Patent Number 7,604,716; is that
` correct?
`A. That is correct, yes.
` MR. FITZPATRICK: Counsel, do you
` have extra copies?
` MS. GRANOVSKY: (Hands documents.)
`BY MS. GRANOVSKY:
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` DR. UWE KORTSHAGEN
`Q. Have you seen this document before?
`A. Yes, I have seen it before.
`Q. And have you reviewed it before?
`A. Yes, I have.
`Q. Let's turn to claim 1 of the '716 patent.
` It's in column 20. Are you there?
`A. Yes, I am.
`Q. And subpart B of the claims reads, "A power
` supply that supplies power to the weakly
` ionized plasma through an electrical pulse
` that is applied across the weakly ionized
` plasma, the electric pulse having at least
` one of a magnitude and a rise time that is
` sufficient to transform the weakly ionized
` plasma to a strongly ionized plasma without
` developing an electrical breakdown condition
` in the chamber"; is that correct?
`A. That is correct, yes.
`Q. What do you understand this claim element to
` mean?
` MR. TENNANT: Objection to form.
` THE WITNESS: I'm wondering
` whether you would be so kind to hand me my
` deposition, because this is a quite complex
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` DR. UWE KORTSHAGEN
` claim element and I would like to refer to
` my -- my declaration to have this discussion.
`BY MS. GRANOVSKY:
`Q. Well, we'll get to your declaration before,
` but I was wondering if you have an
` understanding of what the meaning is without
` looking through your declaration.
`A. I do have an understanding of what the
` meaning is, yes.
`Q. And so can you please tell me what your
` understanding is?
`A. I would like to refer to my declaration to
` make sure that I can give you an accurate
` answer.
`Q. But I would like to see if you can tell me in
` your own words without the declaration what
` you understand the meaning of the -- of this
` element is?
` MR. FITZPATRICK: Counsel, I think
` the witness has indicated he'd like to see
` his declaration. It's not a memory test. I
` think he is entitled -- given the volume of
` papers in this matter --
` MS. GRANOVSKY: I understand
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` DR. UWE KORTSHAGEN
` that --
` MR. FITZPATRICK: -- I think he's
` entitled to see the declaration.
` MS. GRANOVSKY: -- but I would
` like to see if he can give me an
` understanding what this means.
` MR. FITZPATRICK: Right. But I
` think that's exactly the point, he's just
` indicated that he would like to refer to his
` declaration in order to be able to do that.
`BY MS. GRANOVSKY:
`Q. So as you sit here right now, you cannot give
` me an answer as to what this -- what this
` element means?
`A. Dr. Granovsky, I think that it's important
` that in this case we all strive for accuracy.
` And because this patent involves, I believe,
` four declarations, four board decisions which
` total altogether probably 3 or 400 pages, I
` would like to make sure that I can give you
` an accurate answer, and for this reason I
` would like to review my declaration.
`Q. Okay. Just a moment, I will get you the
` declaration. (Hands document.)
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` DR. UWE KORTSHAGEN
`A. Thank you.
` MR. TENNANT: Counsel, are we
` marking this Exhibit 2?
` MS. GRANOVSKY: We will use the
` Intel number.
`BY MS. GRANOVSKY:
`Q. I've handed you an exhibit that was earlier
` marked as Intel 1002 in IPR Number 2004 --
` 2014 -- 2014-01099; is that correct?
`A. Can you point me to where the IPR number is?
`Q. I apologize, it wouldn't be on this.
`A. Aha. Okay. I see that it's Intel 1002,
` correct, yes.
`Q. Do you recognize this document?
`A. I do.
`Q. What is it?
`A. It is my declaration concerning claims 1
` through 11 and claims -- claim 33 of the
` patent 7,604,716.
`Q. Okay. And so now coming back to my earlier
` question about subpart B of claim 1, do you
` have an understanding of what this claim
` element means?
`A. Let me take a look. (Reviews document.)
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` MR. TENNANT: Same objection.
` THE WITNESS: So the answer is I
` do have an understanding of what element B
` means.
`BY MS. GRANOVSKY:
`Q. Can you explain to me what your understanding
` is?
`A. If I were to summarize it in one sentence, I
` could read to you limitation B --
`Q. Well, I would like to understand --
`A. -- again.
`Q. -- what your understanding of that limitation
` is in --
`A. Aha.
`Q. -- your own words.
`A. Are there specific points where you require
` my explanation or is it for the entire claim
` elements?
`Q. It's for the entire claim element.
`A. Aha. Okay. "A power supply that supplies
` power to the weakly ionized plasma," so this
` obviously talks about a power supply that
` supplies power to a weakly ionized plasma,
` "through an electrical pulse that is applied
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` DR. UWE KORTSHAGEN
` across the weakly ionized plasma," so it
` talks about an electrical pulse that is
` applied across the weakly ionized plasma,
` "the electrical pulse having at least one of
` a magnitude and a rise time," so it means it
` has either a magnitude or a rise time or both
` and that this one of a magnitude of a rise
` time should be sufficient to transform the
` weakly ionized plasma to a strongly ionized
` plasma and that this should occur without
` developing an electrical breakdown condition
` in the chamber.
`Q. Okay. Is it your understanding that the
` electrical pulse -- that the magnitude or the
` rise time or both of the electrical pulse
` should trans -- should be sufficient to
` transform the weakly ionized plasma to a
` strongly ionized plasma without developing an
` electrical breakdown condition in the
` chamber?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: Could you breakdown
` the question and is it possible to break this
` down into a shorter question?
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` DR. UWE KORTSHAGEN
` MS. GRANOVSKY: Not really,
` because it's a long phrase.
` THE WITNESS: Well, then I hope
` you excuse me if I ask you to ask the
` question again or read it to me again very
` slowly, please.
` MS. GRANOVSKY: Sure.
`BY MS. GRANOVSKY:
`Q. Is it your understanding that the magnitude
` or the rise time or both of the electrical
` pulse should be sufficient to transform the
` weakly ionized plasma to a strongly ionized
` plasma without developing an electrical
` breakdown condition in the chamber?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: It is my
` understanding that this is what limitation B
` of claim 1 requires, yes.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. Is it your understanding that the magnitude
` and the rise time or both of the electrical
` pulse should be sufficient to eliminate the
` development of an electric breakdown
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` DR. UWE KORTSHAGEN
` condition in the chamber?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: I don't think that
` this is what the claim language requires.
`BY MS. GRANOVSKY:
`Q. Why not?
`A. Because the claim language requires that at
` least one of a magnitude and a rise time that
` is sufficient to transform the weakly ionized
` plasma to the strongly ionized plasma without
` forming an electrical breakdown condition.
` So maybe you -- you want to read your
` question again so that I can completely
` understand what you actually asked.
`Q. Sure. Is it your understanding that the
` magnitude or the rise time or both of the
` electrical pulse should be sufficient to
` eliminate the development of an electrical
` breakdown condition in the chamber?
` MR. FITZPATRICK: Same objections.
` THE WITNESS: This is not my
` understanding of the claim language. My
` understanding of the claim language is that
` at least one of a magnitude and a rise time
`
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` should be sufficient to transform the weakly
` ionized plasma to a strongly ionized plasma.
`BY MS. GRANOVSKY:
`Q. Is there any relationship between the
` magnitude or the rise time or both of the
` electrical pulse and the development of an
` electrical breakdown condition in the
` chamber?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: (Reviews document.)
` Could you repeat the question, please?
` MS. GRANOVSKY: Sure.
`BY MS. GRANOVSKY:
`Q. Is there any relationship between the
` magnitude or the rise time or both of the
` electrical pulse and the development of an
` electrical breakdown condition in the
` chamber?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: Well, the answer is
` I don't know.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. What would you need to know in order to
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` DR. UWE KORTSHAGEN
` answer this question?
`A. So I think the answer is that I do believe
` that -- that it is possible that there is a
` relation between the magnitudes of an
` electrical pulse and the development of an
` electrical breakdown condition.
`Q. What about the rise time?
`A. For that I really do not have an answer. I
` do not have an answer.
`Q. So what -- what is your understanding of what
` rise time means?
`A. My understanding of rise time means -- my
` understanding of rise time is that this is
` the time required to transition from one
` level of power to another level of power.
`Q. And if the transition is slow versus a
` transition that is fast, would that have an
` impact -- potential impact on the breakdown
` conditions in the chamber?
` MR. FITZPATRICK: Objection to
` form.
` THE WITNESS: I could see if your
` rise time is really slow so that it results
` in a very long pulse, that this could
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` DR. UWE KORTSHAGEN
` potentially favor the development of
` electrical breakdown conditions, which I take
` to mean as an umbrella term for
` instabilities.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. So there is a potential relationship between
` the rise time and the development of
` electrical breakdown conditions; is that
` correct?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: Yes, I think that
` under certain conditions, an unwise choice of
` the rise time may favor electrical breakdown
` conditions.
`BY MS. GRANOVSKY:
`Q. Is there an interplay between the magnitude
` of the pulse and the rise time of the pulse
` that could influence the development of
` electrical breakdown conditions in the
` chamber?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: Yes, I think there
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` DR. UWE KORTSHAGEN
` could be an interplay.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. What would that interplay be?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: I don't believe that
` I can give you a specific answer, because I
` think there could be a large combination of
` variables which could play into that. So I
` don't think I could give you an answer which
` says if the rise time is this and the
` magnitude is that, then you will have
` electrical breakdown conditions. I don't
` think that this is possible.
`BY MS. GRANOVSKY:
`Q. So it would require a lot of experimentation
` to come up with the right combination of
` magnitude and rise time to minimize the
` development of electrical breakdown
` conditions in the chamber?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: I do not believe
` that it takes a lot of experimentation to get
` to that point. I do believe that it takes a
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` general understanding of how plasmas work and
` under which conditions they develop
` electrical breakdown conditions. I have to
` add that I don't really like the term
` electrical breakdown condition --
`BY MS. GRANOVSKY:
`Q. What would you prefer?
` THE WITNESS: -- but I consider
` it -- I consider it an umbrella term for --
` for instabilities, including arcing.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. What other instabilities could there be?
`A. Well, there can be lots of instabilities, I
` believe. I certainly don't know all of them.
`Q. Okay. Can you name a few?
`A. Well, we have talked about arcing. I could
` consider thermal instabilities, and I think
` arcing is likely to be a thermal instability.
` Other kinds of ionization instabilities,
` instabilities related to the presence of
` magnetic fields. And there are probably many
` more which now I don't know.
`Q. Okay. So looking again at subpart B of the
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` DR. UWE KORTSHAGEN
` claim as a whole --
`A. Yes.
`Q. -- is it your understanding that the design
` of this step prevents electrical breakdown
` conditions during the process when a weakly
` ionized plasma is transformed into a strongly
` ionized plasma?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: Could you please
` repeat the question?
` MS. GRANOVSKY: Sure.
` THE WITNESS: Just the relevant
` part, please.
`BY MS. GRANOVSKY:
`Q. Is it your understanding that the design of
` this step prevents electrical breakdown
` conditions during the process when a weakly
` ionized plasma is transformed into a strongly
` ionized plasma?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: Yeah, it is my -- my
` understanding that limitation B requires that
` there is no development of an electrical
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` breakdown condition in the chamber during the
` transformation from the weakly to the
` strongly ionized plasma.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. And is it your understanding that this
` requirement depends on choosing the right
` magnitude or the right rise time of the
` electrical pulse?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: So if I read
` limitation B, it talks about the electrical
` pulse having a magnitude and a rise time. It
` doesn't talk about choosing.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. So if the electrical pulse has a magnitude or
` a rise time or both that creates electrical
` breakdown conditions in the chamber, would
` that process be covered by this subpart, by
` this claim?
` MR. FITZPATRICK: Object to form.
` THE WITNESS: I think if the
` magnitude and the rise time of the pulse was
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` DR. UWE KORTSHAGEN
` such that you had an electrical breakdown
` condition occurring during each -- during
` each transformation from a weakly to a
` strongly ionized plasma, then this would not
` be covered by limitation B.
`BY MS. GRANOVSKY:
`Q. So this -- your understanding is that
` subpart B requires simply reducing the
` probability of having an electrical breakdown
` condition in the chamber?
` MR. FITZPATRICK: Object to the
` form, mischaracterizes the testimony.
` THE WITNESS: Yeah, this claim
` element does not talk about probabilities, so
` from that point of view I would not want to
` read probability into this claim element.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. It talks about without developing an
` electrical breakdown condition in the
` chamber; is that correct?
`A. That is correct, yes.
`Q. What is your understanding of without
` developing an electrical breakdown condition
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` is?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: Well, my
` understanding is that without developing an
` electrical breakdown condition means that you
` are not developing an instability, which Zond
` choose to name an electrical breakdown
` condition.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. And so isn't there a choice to be made about
` the magnitude or the rise time of the
` electrical pulse if a person of skill in the
` art wanted to follow this claim?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: I think if within
` the framework of claim number 1 the patent
` owner would have thought that there is a
` choice to be made, then I'm sure that the
` patent owner would have mentioned it in this
` claim element.
` MS. GRANOVSKY: Okay.
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`BY MS. GRANOVSKY:
`Q. So let's talk about the electrical pulse for
` a moment. What is your understanding of what
` an electrical pulse is within the context of
` this claim?
`A. We are talking about claim number 1 still --
`Q. Yes.
`A. -- the electrical pulse? Aha.
` Yeah, the term electrical pulse is a
` little bit vague. And from that point of
` view, my understanding is that it could be a
` power pulse, a voltage pulse or a current
` pulse. And the understanding is that all of
` these electrical quantities are coupled to
` each other, so that means that a power pulse
` will involve a voltage pulse and a current
` pulse.
`Q. So it is possible that this claim discusses
` having a magnitude and the rise time that is
` sufficient to transform the weakly ionized
` plasma to a strongly ionized plasma without
` developing an electrical break down condition
` of a voltage pulse; is that correct?
` MR. FITZPATRICK: Object to the
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` form.
` THE WITNESS: I think, as I said,
` it is possible that this claim refers to a
` voltage pulse, it is possible that this claim
` refers to a power pulse, and it is possible
` that this claim refers to a current pulse
` with the understanding that all of these
` three quantities are coupled to each other.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. But it is possible that the magnitude and the
` rise time of a voltage pulse is sufficient to
` transform the weakly ionized plasma to a
` strongly ionized plasma without developing an
` electrical breakdown condition in the
` chamber; is that correct?
` MR. FITZPATRICK: Object to the
` form.
` THE WITNESS: I think you are
` correct, it is possible that claim element B
` refers to a voltage pulse, yes.
` MS. GRANOVSKY: Okay.
`BY MS. GRANOVSKY:
`Q. So is it your understanding that according
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` to this limitation, it is important to
` control the magnitude or the rise time or
` both of the electrical pulse to prevent
` developing an electrical breakdown condition
` in the chamber?
` MR. FITZPATRICK: Object to the
` form of the question.
` THE WITNESS: Could you be so kind
` to repeat your question, please?
` MS. GRANOVSKY: Sure.
`BY MS. GRANOVSKY:
`Q. Is it your understanding that according to
` this limitation, it is important to control
` the magnitude or the rise time or both of the
` electrical pulse to prevent developing an
` electrical breakdown condition in the
` chamber?
` MR. FITZPATRICK: Same objection.
` THE WITNESS: That is not my
` understanding. It is my understanding that
` the claim says that it is important -- excuse
` me, it doesn't say important, so let me start
` over again.
` I think claim element B says that the
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` electrical pulse needs to have at least one
` of a magnitude and a ri
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