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` OVERZET- 5/8/15
` UNITED STATES PATENT AND TRADEMARK OFFICE
` -----------------------------------------
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` -----------------------------------------
`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 COMPANY,
` Petitioners,
`vs.
`
`ZOND, LLC,
`
` Patent Owner.
`
` Patent 6,853,142 B2
`--------------------------------------------
` IPR Case Nos. IPR2014-00818, 00819,
` 00821, 00827, 01098
`--------------------------------------------
`
` VIDEOTAPED DEPOSITION OF
` LAWRENCE J. OVERZET PH.D.
` DALLAS, TEXAS
` MAY 8, 2015
`
`Reported by: Susan S. Klinger, RMR-CRR, CSR
`Job No. 93423
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` OVERZET- 5/8/15
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` May 8, 2015
` 3:33 p.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.
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` OVERZET- 5/8/15
`A P P E A R A N C E S:
`
`Attorneys for GlobalFoundries:
` Mr. David Tennant, Esq.
` WHITE & CASE
` 701 Thirteenth Street, N.W.
` Washington, D.C. 20005
`
`Attorneys for Defendant(s):
` Mr. Gregory Gonsalves, Esq.
` GONSALVES LAW FIRM
` 2216 Beacon Lane
` Falls Church, Virginia 22043
`
`Also Present:
` Mr. Jay Wiggins, videographer
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` OVERZET- 5/8/15
` VIDEOGRAPHER: This is the start of
`tape labeled number 1 in a videotaped
`deposition of Dr. Overzet in the matter of
`Fujitsu versus Zond in the United States
`Patent and Trademark Office, case
`IPR2014-00818, 00819, 00821, 00827, 01098,
`patent number 6,853,142 B2. This
`deposition is being held at Baker Botts,
`2001 Ross Avenue, Dallas, Texas on May 8th,
`2015, and the time is approximately 3:34
`p.m.
` My name is Jay Wiggins. I'm a legal
`video professional representing TSG
`Reporting headquartered at 747 Third
`Avenue, New York, New York. The court
`reporter is Susan Klinger in association
`with TSG Reporting.
` Will counsel please introduce
`yourselves.
` DR. GONSALVES: My name is
`Dr. Gregory Gonsalves representing Zond.
` MR. TENNANT: My name is David
`Tennant of White & Case. I'm representing
`GlobalFoundries.
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` OVERZET- 5/8/15
` VIDEOGRAPHER: Will the court
` reporter please swear in the witness.
` MR. TENNANT: Just for the record,
` my objections will apply to all
` petitioners.
` DR. LAWRENCE OVERZET,
`having been first duly sworn, testified as
`follows:
` EXAMINATION
`BY DR. GONSALVES:
` Q. Dr. Overzet, could you turn your
`attention to Figure 1 of the Wang reference,
`please.
` A. Yes.
` Q. Do you see where it says in item
`number 32, Ar?
` A. Yes.
` Q. Does that stand for argon?
` A. I believe it does.
` Q. And argon is a gas; correct?
` A. A noble gas.
` Q. Is item number 34 a valve?
` A. It is not.
` Q. What is it?
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` A. Wang identifies item 34 in column 4,
`the first paragraph around line 7 -- no, 6 as a
`mass flow controller.
` Q. Does gas enter Wang's chamber at the
`lower right portion?
` A. This is a schematic of Wang, of the
`system. In the schematic it shows gas entering
`in the lower right portion.
` Q. Is item 38 a vacuum pump?
` A. Almost. Wang identifies item 38 is
`a vacuum system.
` Q. Is item 40 in Figure 1 of Wang a
`pumping port?
` A. This is what -- this is how Wang
`identifies item 40, yes.
` Q. Does the vacuum system identified by
`reference number 38 pump gas out of the chamber
`in Figure 1 of Wang?
` A. Did you say the vacuum system 38?
` Q. Yes.
` A. Yes, I would expect the vacuum
`system 38 to pump gas out of the chamber in
`Wang.
` Q. Does gas in the chamber of Wang
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` OVERZET- 5/8/15
`showed in Figure 1 leave the chamber at the
`pumping port?
` A. In that schematic, that would be a
`place where gas leaves the chamber.
` Q. Do you see a pedestal in Figure 1
`identified as reference number 18?
` A. I do see it.
` Q. Does gas flow around the pedestal
`from where it enters in the lower right corner
`of the chamber of Wang?
` A. I'm not sure I understand the detail
`of that question. Can you state that again or
`state it a little more precisely?
` Q. Well, we're looking at a picture in
`two dimensions in Figure 1; is that correct?
` A. Yes.
` Q. But it's representing a device that
`is in a three-dimensional world; correct?
` A. Yes.
` Q. And so the device would have three
`dimensions?
` A. I would expect so.
` Q. All right. So in the
`three-dimensional device that is represented in
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`this two-dimensional figure, is there a path
`around the -- the bottom portion of the
`pedestal for the gas to flow?
` A. There a gap is shown between the
`pedestal 18 and the item 24 and 36, in which I
`expect gas can flow and fill.
` Q. Does the gas that enters the chamber
`in Figure 1 of Wang move toward the pumping
`part -- pumping port identified by item number
`40?
` A. I'm sorry, I was looking at
`something else and I missed the detail of your
`question. Would you please repeat it for me?
` Q. Sure, no problem. Does the gas that
`enters the chamber of Figure 1 of Wang move
`toward the pumping port identified by item
`number 40?
` MR. TENNANT: Objection, form.
` A. Eventually.
` Q. Dr. Overzet, I'm going to hand you a
`copy of U.S. Patent 6,853,142, and if it's okay
`with you, I'll refer to this as the '142
`patent. Could you direct your attention to
`Figure 2C, please?
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` OVERZET- 5/8/15
` A. Uh-huh.
` Q. Does feed gas enter the chamber at
`the area identified by the reference number 226
`in Figure 2C of the '142 patent?
` A. My understanding of Figure 2C is
`that 226 does not represent an area.
` Q. What does 226 represent?
` A. I see in column 9 of the '142 patent
`around line 16 that 226 identifies the feed
`gas.
` Q. Does the feed gas -- let me start
`over. Does feed gas identified as item number
`226 enter the chamber of the '142 patent that
`is shown in Figure 2C?
` MR. TENNANT: Objection, form.
` A. So the question is simply, does feed
`gas enter the chamber of Figure 2C in its
`essence; am I right?
` Q. Right. That's what I asked.
` A. A chamber is not shown in Figure 2C,
`but assuming that region 232 represents a
`portion of a chamber volume, then the answer is
`yes. Actually 232 does not represent a portion
`of a chamber volume, but I don't know what to
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` OVERZET- 5/8/15
`use as a representation of that chamber volume,
`so...
` Q. Does Figure 2C show strongly-ionized
`plasma?
` MR. TENNANT: Objection, relevance.
` A. In my reading of the specification,
`I am not finding a strongly-ionized plasma
`referenced until one refers to Figure 2D, a
`weakly-ionized plasma is related to Figure 2C.
`What the text size says and starting in line
`57, referring to Figure 2C, "Once the
`weakly-ionized plasma is formed," etcetera.
`Then again in column 7, beginning at line 23,
`referring to Figure 2D, "The high-power pulses
`generate a highly-ionized or a strongly-ionized
`plasma 238."
` If I come back to Figure 2C, I do
`not see a strongly-ionized plasma 238
`referenced on that figure.
` Q. Can you please direct your attention
`to Figure 2D?
` A. Yes.
` Q. In your opinion, does the feed gas
`that enters the chamber at the left side of
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`Figure 2D tend to push the strongly-ionized
`plasma toward the center of the figure?
` MR. TENNANT: Objection, form and
` relevance.
` A. I do not remember reading about such
`a question to be answered in my declaration. I
`do remember that with respect to gas flow that
`the board construed a means for diffusing. My
`understanding is that the board construed a
`means for diffusing the strongly-ionized plasma
`with additional feed gas to allow additional
`power to be absorbed by the strongly-ionized
`plasma was addressed in paragraph 44 as at the
`end of that paragraph, "providing a feed gas to
`the strongly-ionized plasma sufficiently to
`allow additional power to be absorbed by the
`strongly-ionized plasma."
` There's no discussion of so-called
`pushing at that point.
` Q. Is it your opinion that one of
`ordinary skill in the art would understand that
`gas entering the left side of Figure 2D would
`tend to push the strongly-ionized plasma to the
`center of Figure 2D?
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` MR. TENNANT: Objection, form and
` relevance.
` A. The idea of gas entering the reactor
`and the salient points of gas entering a
`reactor are -- are discussed in my declaration
`beginning on page 35, paragraph 73 and
`following.
` THE WITNESS: Would you read back
` the question.
` (Record read.)
` MR. TENNANT: Objection, form and
` relevance.
` A. I will go to my paragraph 77.
`That's where I state that there will be a small
`pressure gradient in the reactor chamber
`because of the new gas entering the chamber and
`the old gas being pumped out. That causes in
`this case discussing Wang's feed gas to diffuse
`into the plasma near the target.
` Q. Well, my question was directed
`towards the -- the device in the '142 patent
`and not Wang in particular with respect to the
`Figure 2D.
` A. Uh-huh.
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` Q. So would one of ordinary skill in
`the art understand that gas entering the left
`side of Figure 2D would tend to push the
`strongly-ionized plasma to the center?
` MR. TENNANT: Objection to form and
` relevance.
` A. One of ordinary skill in the art
`would understand that diffusing and pushing are
`two separate things, and in my declaration, I
`addressed the idea of diffusing into the
`plasma, but I do not address or discuss
`anything about a so-called concept of pushing.
` Q. So would you understand that one of
`ordinary skill in the art -- strike the
`question. Let me start over.
` Would one of ordinary skill in the
`art understand that gas entering the left
`portion of 2D would tend to push the
`strongly-ionized plasma to the center of Figure
`2D?
` MR. TENNANT: Objection, form,
` relevance, asked and answered.
` A. I would refer again to my paragraph
`77.
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` OVERZET- 5/8/15
` Q. Doesn't your paragraph 77 refer to
`Wang?
` A. It does --
` Q. Well, my question was with respect
`to the '142 patent.
` A. -- but it's relevant -- understood.
` Q. Okay.
` A. But it presents the relevant
`information that actually is relevant to
`both --
` Q. Okay. So does paragraph --
` A. -- that I stated just before.
` Q. Okay. Does paragraph 77 indicate to
`you that gas entering the left portion of
`Figure 2D would tend to push the
`strongly-ionized plasma to the center of Figure
`2D?
` MR. TENNANT: Objection, form.
` A. In my prior response I indicated
`that one of ordinary skill in the art would
`understand pushing, whatever that means, and
`diffusing to be two separate processes. I
`guess I called that things before, and in my
`declaration, I address only diffusing.
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` Q. Do you have an opinion as to whether
`or not gas entering the left-hand side of
`Figure 2D would tend to push the
`strongly-ionized plasma to the center?
` MR. TENNANT: Objection, form and
` relevance.
` A. That is a complex issue, because
`more than collisions are involved more than --
`yes. So I do have an opinion.
` Q. What is your opinion as to whether
`or not gas entering the left-hand side of
`Figure 2 would tend to push the
`strongly-ionized plasma to the center?
` MR. TENNANT: Objection, form and
` relevance.
` A. My understanding is that diffusion
`is a completely separate process phenomenon
`from what you are calling pushing. From my
`understanding of gas flow, gas motion, my
`understanding is that diffusion occurs -- I'm
`sorry, gas flow rather occurs by neutral gas
`flow occurs by diffusion. At the pressures and
`distances, conditions envisioned in the '142
`patent, I believe that pushing would be
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` OVERZET- 5/8/15
`minimal.
` Q. Can you return your attention to the
`Wang patent?
` A. I think this --
` Q. Yeah, that's it. And the Wang
`patent has a rotating magnet; is that correct?
` A. That is my understanding.
` Q. Would the speed at which a magnet in
`Wang is rotated affect the uniformity of the
`plasma density beneath it?
` MR. TENNANT: Objection, form.
` A. Can you be more specific for me in
`identifying what fashion you think that
`uniformity might be affected?
` Q. I'm asking you whether it would be
`affected.
` MR. TENNANT: Objection, form.
` Q. So the magnet --
` A. Do you mean a global uniformity or a
`local uniformity?
` Q. Well, what do you mean by "global
`uniformity"?
` A. That's described in my declaration
`in Overzet Figure 2.
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` Q. Okay. So would the speed at which
`the magnet is rotated in Wang affect what you
`refer to as the global uniformity of the plasma
`density?
` MR. TENNANT: Objection, form.
` A. This is related to the discussion in
`my declaration at page 51 -- hopefully page
`51 --
` Q. Can you refer --
` A. -- paragraph 104.
` MR. TENNANT: Just try to refer to
` the paragraph numbers.
` THE WITNESS: Yes.
` MR. TENNANT: Thanks.
` A. Paragraph 104 and following. I'm
`sorry, paragraph 170 -- 107 and following,
`where I write: "To the extent it is determined
`that the claim requires for the plasma to be
`globally uniform over the entire surface of the
`cathode (which I believe goes beyond the
`broadest reasonable interpretation of the
`claims) Wang teaches that as well. As shown in
`my figure above," that's this Overzet Figure 2,
`"referring specifically to the bottom part of
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`the figure designated as 'Over time.' Wang
`describes that the rotation of the magnet moves
`the uniform strongly-ionized plasma to provide
`a resulting electric field and plasma that are
`uniform over the entire surface of the
`cathode/target. This means that the uniformity
`of the plasma is a direct result of" three --
`"of two things" rather. "(1) the amplitude and
`pulse width of the electric field spreading out
`the plasma under the magnet; and (2) the magnet
`rotation causing the plasma to cover the entire
`surface of the cathode/target over time." Item
`2, the magnet rotation describes the conditions
`by which the magnet is rotating.
` Q. And how would the speed of the
`rotation of the magnet affect the density of
`the plasma beneath it? Strike the question.
`I'll ask another one.
` How would the speed of the rotation
`of the magnet affect what you refer to as the
`global uniformity of the plasma beneath it?
` A. My understanding of the appropriate
`answer for your question includes an
`examination of Wang's Figure 5 and his
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`discussion of Figure 5 in Column 6 where he
`says, amongst other things, that the rotation
`period taum needs to be desynchronized from the
`waveform characterized -- character -- waveform
`of the target pulses 82 characterized by
`repetition tauP. I guess, perhaps a shorter
`version of this is that next sentence: "This
`relationship is mathematically expressed as tau
`sub m and tau sub p being incommensurate.
` Q. Could you -- are you finished with
`your answer?
` A. Yes.
` Q. Could you turn your attention to the
`'142 patent?
` A. Okay.
` Q. Does the '142 patent disclose an
`electrode as a preionizing filament electrode
`that is a component in an ionization source
`that generates weakly-ionized plasma?
` MR. TENNANT: Objection, form and
` relevance.
` Q. If it will help, you can refer to
`the '142 patent at column 16 around line 29.
` A. Column 16, line 29?
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` Q. Of the '142 patent.
` A. Column 16, line --
` Q. Around line 29. I'll repeat the
`question if it makes it easier for you. Does
`the '142 patent disclose an electrode as a
`preionizing filament electrode that is a
`component in an ionization source that
`generates weakly-ionized plasma?
` MR. TENNANT: Objection, form and
` relevance.
` A. So the line to which you directed me
`in column 16 refers to Figure 16A and does --
`and states simply, "The plasma generating
`system 200 prime of Figure 6A includes an
`electrode 452 that generates a weakly-ionized
`or preionized plasma."
` The next sentence is what you want
`as well. "The electrode 452 is also referred
`to as a preionizing filament electrode and is a
`component and an ionization source that
`generates the weakly-ionized plasma."
` Q. Can you turn your attention to
`Figure 6A of the '142 patent remember. Does
`Figure 6A show an anode as reference number
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`216?
` MR. TENNANT: Objection, relevance.
` A. Going back to that column as well,
`it does in the specification identify -- the
`specification does identify 216 as an anode.
` Q. Does Figure 6A show a cathode
`identified as reference number 204?
` MR. TENNANT: Objection, relevance.
` A. It does appear in that column 16 to
`identify 204 as a cathode.
` Q. Does Figure 6A show that the
`preionizing filament electrode identified as
`452 is separate from the anode identified as
`216 and the cathode identified as 204?
` MR. TENNANT: Objection, relevance,
` form.
` A. It identifies it as a separate
`element. I would note, as I did in my
`declaration in paragraph 127 and 128, that the
`cathode and anodes are also electrodes, so that
`in Figure 6A I see three -- a minimum of three
`electrodes, only one of which is identified as
`a filament electrode.
` Q. Could you turn your attention to
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`Figure 2C of the '142 patent, please.
` A. Figure 2C.
` Q. Is the weakly-ionized plasma of the
`'142 patent positioned partially in the gap
`shown in Figure 2C?
` MR. TENNANT: Objection, form and
` relevance.
` A. Dr. Gonsalves, I'm going to need to
`do a little bit more reading still to answer
`that question. I spent most of my time -- no,
`I want to make sure I do understand what's
`going on in Figure 2C as opposed to Figure 2D
`and the discussion in the specification runs
`back and forward.
` In this discussion relating to
`Figure 2C, I do not find the specification
`discussing weakly-ionized plasma in that
`region. I do find there being discussion of
`weakly-ionized plasma with respect to Figure 2D
`and I believe Figure 2B, but in Figure 2C, I
`only find the weakly-ionized plasma being
`discussed as in region 232, and in Figure 2B,
`it's made clear that the region 232 does not
`extend into the region 222, which I believe to
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`be the region that you asked me about.
` Q. Does any portion of the '142 patents
`indicate that weakly-ionized plasma is
`positioned in the gap?
` A. In the region 222?
` Q. Right, 222 shows a gap.
` A. In column 8 I read, "A preionizing
`voltage is applied between the cathode 204 and
`the anode 216 across the feed gas 226 to form
`the weakly-ionized plasma," but then it
`references 232.
` The next sentence, however, says,
`"The weakly-ionized plasma 232 is generally
`formed in the region 222 and diffuses to the
`region 234 as the feed gas 226 continues to
`flow."
` 234, I only find listed as the
`strongly-ionized plasma in Figure 2D. So --
` Q. So in --
` A. Go ahead.
` Q. I'm sorry.
` A. No, go ahead.
` Q. So in light of what you just read,
`do you have an opinion as to whether a portion
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`of the weakly-ionized plasma is positioned in
`the gap in the '142 patent?
` MR. TENNANT: Objection to form,
` mischaracterizes testimony.
` A. Do you mean in Figure 2C?
` Q. In any figure of the '142 patent, do
`you have an opinion as to whether a portion of
`the weakly-ionized plasma is positioned in the
`gap?
` A. I -- an opinion. Since the authors
`say in column 8 that the weakly-ionized plasma
`232 is generally formed in the region 222, I
`would take that to mean that the authors
`envisioned some weakly-ionized plasma in the
`region 222 at some point.
` Q. Can you turn your attention back to
`the Wang reference, please?
` A. Okay. I'm there.
` Q. Does Wang disclose a grounded shield
`identified by reference number 24 that protects
`the chamber walls from sputter deposition?
` MR. TENNANT: Objection, form.
` A. I see at the bottom of column 3,
`line 66 and 67, "the grounded shield 24
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`protects the chamber walls from sputter
`deposition and also acts as a grounded anode
`for the cathode."
` Q. Does Wang also disclose a floating
`shield identified by reference number 26 that
`is supported by a second dielectric isolator?
` MR. TENNANT: Objection, relevance.
` A. In column 4, lines 1 and 2 -- shall
`I read it?
` Q. So is it your testimony that at
`column 4, lines 1 and 2, Wang discloses a
`floating shield identified by reference number
`26 that is supported by a second dielectric
`isolator?
` MR. TENNANT: Objection, relevance.
` A. 28? Yes, that was read verbatim
`from Wang.
` Q. Can you take a look at Figure 1 of
`Wang?
` A. Yes.
` Q. Is item 14 in Figure 1 of Wang a
`cathode at the top of the chamber?
` A. Item 14 is described by Wang both as
`a cathode and as a sputtering target.
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` Q. Is Item 24 in Figure 1 of Wang a
`grounded shield acting as an anode along the
`sides and bottom of the chamber?
` A. Are you asking me if item 24 is
`grounded?
` Q. No, I'm asking -- well, I'm asking
`you a little bit more than that. I'm asking if
`item 24 in Figure 1 of Wang is a grounded
`shield acting as an anode.
` A. I believe I've already answered
`that. That's the bottom of column 3 and the
`top sentence of column 4.
` Q. Is the purpose of the floating
`shield in Wang to focus sputtered metal ions
`toward the wafer?
` A. Wang says in column 4, "A floating
`shield 26" -- this is what you are referencing?
` Q. I asked you if the purpose of the
`floating shield in Wang is to focus sputtered
`metal ions toward the wafer?
` MR. TENNANT: Objection, relevance.
` A. Wang discusses his floating shield
`26 in the following words: It is supported on
`a second dielectric isolator 21 -- 28, rather,
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` OVERZET- 5/8/15
`becomes negatively charged in the presence of a
`high=density plasma and acts to focus sputtered
`metal ions towards the wafer 20.
` Q. So in light of what you just read,
`would you conclude that the purpose of the
`floating shield in Wang is to focus sputtered
`metal ions toward the wafer?
` MR. TENNANT: Objection, relevance.
` A. No, but that, in fact, that is
`something which it accomplishes.
` Q. Is it your opinion that one of the
`purposes of the floating shield in Wang is to
`focus sputtered metal ions toward the wafer?
` MR. TENNANT: Objection, relevance,
` asked and answered.
` A. Wang indicates that the floating
`metal -- that the floating shield accomplishes
`a function of becoming negatively charged and
`focusing sputtered metal ions towards the
`wafer, but I wasn't part of the design of this
`chamber. So to talk about the purpose someone
`had for it is to ask me to think about what
`other people are thinking.
` Q. Well, I'm just wondering what you're
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`thinking, and in particular, whether you think
`that one of the purposes of the floating shield
`in Wang is to focus sputtered metal ions toward
`the wafer?
` MR. TENNANT: Objection, asked and
` answered.
` A. Wang indicates that this is
`something which the shield 26 accomplishes.
` Q. Does Wang have any disclosure that
`teaches how the ionization rate varies with the
`dimension of the gap between an anode and a
`cathode?
` A. This question is addressed in my
`declaration beginning at paragraph 120, it's
`clear in paragraph 121 I indicate that it's --
`that there is apparently no disagreement that
`Wang teaches a gap.
` In paragraph 122, it's
`unquestionably the case that Wang teaches
`producing an electric field across its gap, and
`that the dimensions of the gap between the
`cathode and electrode are chosen to increase an
`ionization rate of the excited atoms in the
`weakly-ionized plasma.
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` Q. You're finished with your answer?
` A. Yes.
` Q. So in light of what you just read
`from paragraph 120 and paragraph 121 --
`actually, strike the question.
` I'll hand to you a patent 6,190,512
`by Lantsman, and if it's okay with you, I will
`refer to this document by the name Lantsman.
` MR. TENNANT: If we're switching
` topics, we've been going for an hour and
` 15. I suggest a very short break.
` DR. GONSALVES: I have less than
` four minutes, so we can try to hurry.
` MR. TENNANT: The witness is tired,
` so I'll leave it up to him.
` DR. GONSALVES: All right. Try to
` come back as soon as you can.
` VIDEOGRAPHER: Going off record at
` 4:51 p.m.
` (Recess 4:51 p.m. to 4:59 p.m.)
` VIDEOGRAPHER: Back on record at
` 4:59 p.m.
` Q. Could you please turn your attention
`to the Lantsman reference that I handed to you?
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` A. Uh-huh.
` Q. And would you agree that Lantsman
`discloses two DC power supplies?
` A. In this -- the abstract Lantsman
`makes mention of a secondary power supply,
`which pre-ignites the plasma.
` Q. Turning your attention to column 4,
`lines 11 through 19, would you agree that
`Lantsman discloses two DC power supplies?
` A. Column 4, lines 11 to 19?
` Q. Yes, around there.
` A. Is there a difference between this
`question and the immediately prior question?
` Q. I'm not sure. But my question is --
`my question is simple. It is, would you agree
`that Lantsman discloses two DC power supplies?
` A. And in the abstract, Lantsman notes
`a secondary power supply. If it's secondary,
`then he also has a primary also in the
`abstract.
` Q. And are the primary and secondary
`power supplies in Lantsman DC power supplies?
` A. They're both listed as DC power
`supplies in his Figure 5.
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` Q. Does the sputtering device process
`plasma, in your opinion?
` MR. TENNANT: Objection, form.
` A. Does a sputtering device process
`plasma?
` Q. Correct.
` A. Would you please define those words
`in different words?
` Q. Well, what -- does the phrase
`"process plasma" have a meaning to you?
` A. Yes.
` Q. And what is that meaning?
` A. It is a plasma that is used to
`accomplish a process.
` Q. And so using that definition, would
`a sputtering device, in your opinion, have a
`process plasma?
` MR. TENNANT: Objection, form.
` A. A sputtering device that has a
`plasma in it, one would -- of ordinary skill in
`the art would
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