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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`
`THE GILLETTE COMPANY, et al.,
`
` Petitioners, Patent No. 6,805,779
` IPR2014-00828
` IPR2014-00829
` -vs- IPR2014-00917
` IPR2014-01073
` IPR2014-01076
`ZOND, LLC,
`
` Patent Owner.
`________________________________
`
` DEPOSITION of UWE R. KORTSHAGEN, Ph.D.
` Minneapolis, Minnesota
` May 5th, 2015
`
`Reported by:
`Amy L. Larson, RPR
`Job No. 93265
`
`TSG Reporting - Worldwide 877-702-9580
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`APPEARANCES:
` ASCENDA LAW GROUP
` 333 W. San Carlos Street
` San Jose, CA 95110
` By: Tarek Fahmi, Esq.
` For: Zond, LLC
`
`
` WHITE & CASE
` 701 Thirteenth Street, N.W.
` Washington, D.C. 20005
` By: David Tennant, Esq.
` Nathan Zhang, Esq. (via telephone)
` For: Global Foundries
`
` O'MELVENY & MYERS
` 400 South Hope Street
` Los Angeles, CA 90071
` By: Vincent Zhou, Esq.
` For: AMD
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`INDEX:
`EXAMINATION BY: PAGE
`Mr. Fahmi...........................................4
`PREVIOUSLY MARKED EXHIBITS:
`TSMC EXHIBIT 1207...................................6
`Patent No. 5,753,886
`
`TSMC EXHIBIT 1205..................................14
`U.S. Patent 3,761,836
`TSMC EXHIBIT 1206..................................26
`Patent 3,514,714
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`Global Foundries 1221...............................6
`Supplemental Declaration
`Patent 6,805,779
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`Page 4
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` UWE R. KORTSHAGEN, Ph.D.
`THE DEPOSITION OF UWE R. KORTSHAGEN, Ph.D., taken
`on this 5th day of May, 2015, at The Commons
`Hotel, 615 Washington Avenue, S.E., Minneapolis,
`Minnesota, commencing at approximately 10:53 a.m.
`
` UWE R. KORTSHAGEN, Ph.D.,
` a witness in the above entitled action,
` after having been first duly sworn, was
` deposed and says as follows:
`
` EXAMINATION
`BY MR. FAHMI:
`Q. Would you state your name for the record,
` please.
`A. My name is Uwe Richard Kortshagen.
`Q. Dr. Kortshagen, as you know, my name is
` Tarek Fahmi. I'm here representing Zond.
` MR. FAHMI: Counsel, would you
` like to introduce yourselves?
` MR. TENNANT: Sure. My name is
` David Tennant with White & Case here
` representing Global Foundries, and my
` colleague is on the phone, Nate Zhang, he's
` also with White & Case.
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` UWE R. KORTSHAGEN, Ph.D.
` MR. ZHOU: My name is Vincent Zhou
` with the law firm of O'Melveny & Myers, and I
` represent petitioner AMD.
`BY MR. FAHMI:
`Q. Forgive the repeat from this morning, but
` since it's a separate transcript, I know
` you've been deposed before, so just a couple
` of reminders. So that the court reporter can
` maintain a clear record, please give audible
` answers to the questions that I ask. Is that
` all right?
`A. Yes, it is.
`Q. And if I ask a question that you don't
` understand or didn't hear or simply would
` like repeated, just let me know and I'll be
` happy to do so, okay?
`A. Very well.
`Q. And as you're doing, please, if you can wait
` until I finish asking the question, I'll try
` to wait until you finish giving an answer,
` and that way we're not talking over one
` another. And, again, it helps the court
` reporter keep a clear record. Okay?
`A. I understand.
`
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` UWE R. KORTSHAGEN, Ph.D.
`Q. Is there any reason why you cannot give your
` best testimony today?
`A. No.
`Q. Are you taking any medications that may
` affect your memory?
`A. No.
`Q. Any other reasons you couldn't give your best
` testimony?
`A. No.
`Q. I'm going to hand you, Dr. Kortshagen, what's
` been previously marked as Exhibit 1221.
` (Hands document.)
`A. Thank you.
`Q. Do you recognize this exhibit?
`A. I do.
`Q. What is it?
`A. It is my supplemental declaration concerning
` the patent number 6,805,779.
`Q. It's this declaration and the materials that
` are referenced in it that I'd like to discuss
` with you this morning. And I'd like to start
` with the Iwamura reference. And this copy
` that I'm handing you, at least, has been
` previously marked as Exhibit 1207. Do you
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` UWE R. KORTSHAGEN, Ph.D.
` recognize this exhibit?
`A. I do.
`Q. If I refer to it as Iwamura, you'll
` understand I'm speaking about this particular
` exhibit?
`A. I do, yes.
`Q. And the Iwamura reference is one of the items
` that you considered in connection with the
` preparation of your supplemental declaration
` in those proceedings; is that right?
`A. That is correct, yes.
`Q. Is it correct that Iwamura does not discuss
` the use of a magnetic field?
` MR. TENNANT: Objection to form.
` THE WITNESS: I believe it is
` correct that Iwamura does not discuss the use
` of a magnetic field.
`BY MR. FAHMI:
`Q. If I could ask you to turn your attention to
` the passage that begins at column 7,
` approximately line 46, and the couple of
` paragraphs that go through to approximately
` line 59 or 60, if you could read that to
` yourself and let me know when you're done.
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` UWE R. KORTSHAGEN, Ph.D.
`A. Uh-huh. Yes, I will. (Reviews document.)
` Yes, I have read these two paragraphs.
`Q. Is it correct that in these passages Iwamura
` is referring to what's been I think described
` in your declaration as the preexcitation
` unit?
`A. Yes, it is correct that these two paragraphs
` talk, among other things, also about what I
` believe Iwamura also refers to as
` preexcitation unit.
`Q. And just for clarity, could you mark for us
` in Figure 1 where that preexcitation unit is
` located? (Hands pen.)
`A. Thank you. If you would just give me a
` second, please.
`Q. Sure.
`A. (Reviews document.) Yeah, in Figure 1 the
` preexcitation unit would correspond to the
` ultraviolet lamp which is marked with 24 and
` the corresponding windows 22.
`Q. Okay. Can I ask you to circle that portion
` in Figure 1, please?
`A. Has my description not been clear enough?
`Q. I just want to make sure that there's no
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` UWE R. KORTSHAGEN, Ph.D.
` question later on about what it is that is
` the preexcitation unit. Are you unable to
` mark the diagram to show the preexcitation
` unit?
`A. I think my -- my answer has been quite clear
` by identifying the UV lamp 24 as the
` preexcitation unit.
`Q. So you're not going to mark the diagram for
` me?
`A. I think I have provided a very clear answer
` to your question.
`Q. Are you incapable of marking the diagram?
`A. At this point, because I have already, in a
` very clear way, answered your question, I do
` not see a need to produce a drawing here, if
` you allow me to say on the fly, in a way that
` later on I may not be able to supplement or
` correct.
`Q. When was the last time you studied the
` Iwamura reference?
`A. Again, reading it in full and in detail is
` probably a few weeks ago. Reading over it, I
` did over the weekend.
`Q. And during your review over the weekend,
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` UWE R. KORTSHAGEN, Ph.D.
` today being Tuesday, did you have a chance to
` consider what portion of Figure 1 would be
` considered the preexcitation unit?
` MR. TENNANT: Objection to form,
` relevance.
` THE WITNESS: Yes, I think I did
` consider it.
`BY MR. FAHMI:
`Q. So even though you've considered it within
` the past two or three days, sitting here
` today you're not able to mark Figure 1 to
` identify the preexcitation unit; is that
` right?
` MR. TENNANT: Objection to form,
` asked and answered.
` THE WITNESS: I think that the
` preexcitation unit in my declaration and in
` my testimony, answering to your question, is
` clearly identified as the UV lamp 24, and I
` think I have done with that what I'm obliged
` to do.
`BY MR. FAHMI:
`Q. Let's turn back to column 7, the passages
` that I had you read earlier from lines 46
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` UWE R. KORTSHAGEN, Ph.D.
` through 60.
`A. (Complies.)
`Q. Iwamura indicates that at this stage no
` plasma is observed in the inert gas; is that
` right?
`A. That is correct.
`Q. And it's also correct that the gas is later
` activated in the first plasma generation
` unit, right?
`A. That is correct, yes.
`Q. Referring back to Figure 1, can you identify
` the first plasma generation unit, please?
`A. So in Figure 1 the first plasma excitation
` unit is labeled with the letter A and it
` comprises the first pair of electrodes, 26.
` A and 26.B.
`Q. Anything else?
`A. And because power needs to be supplied to
` these electrodes to generate a plasma, one
` should likely include the power supply 28.
`Q. Let's turn to column 4.
`A. (Complies.)
`Q. And the passage from about lines 9 through
` 12, if you could read that and let me know
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` UWE R. KORTSHAGEN, Ph.D.
` when you're done.
`A. Nine to 12 in column 4?
`Q. Please.
`A. (Reviews document.) Yes, I've read that.
`Q. Iwamura makes reference to a plasma density
` at this passage; is that right?
`A. That is correct.
`Q. The plasma density that's referred to at this
` part of Iwamura is not the same as an excited
` atom density; is that right?
` MR. TENNANT: Objection to form.
` THE WITNESS: I believe that one
` of ordinary skill reading this passage would
` understand that plasma density usually refers
` to the density of electrons and ions in the
` plasma which one of ordinary skill would
` understand to consist out of electrons, ions
` and electrically neutral gas species such as
` ground state gas atoms, excited gas atoms and
` metastable gas atoms.
`BY MR. FAHMI:
`Q. So let me see if I understand your statement.
` You're saying that the plasma as a whole
` includes electrons, ions, ground state atoms,
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` UWE R. KORTSHAGEN, Ph.D.
` excited gas atoms and metastable atoms; is
` that right?
`A. That is correct.
`Q. But the plasma density that is referred to in
` column 4 of Iwamura refers only to the
` density of the electrons and the ions; is
` that right?
`A. It is correct that in the plasma literature
` plasmas are usually characterized by their
` density, referring to density of electrons
` and ions as one parameter of the plasma with
` the understanding that there are other
` species than simply electrons and ions in the
` plasma.
`Q. Does the literature that you're referring to
` include the Iwamura reference?
`A. I think because Iwamura is a reference
` referring to the generation of plasmas, as
` such Iwamura is part of the body of the
` plasma literature which uses this common
` understanding that plasmas contain electrons,
` ions, ground state atoms, excited atoms,
` metastable atoms, and one parameter commonly
` used to describe such plasmas is the plasma
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` UWE R. KORTSHAGEN, Ph.D.
` density.
`Q. That density referring to only the ions and
` electrons, correct?
` MR. TENNANT: Objection; asked and
` answered.
` THE WITNESS: Plasma density
` refers to the density of electrons and ions
` with the understanding that there are other
` species, such as excited atoms and metastable
` atoms, also present in the plasma.
`BY MR. FAHMI:
`Q. If you could set that Iwamura reference
` aside, I'm going to hand you what's been
` previously marked as Exhibit 1205.
` (Hands document.)
` Do you recognize Exhibit 1205?
`A. I do.
`Q. What is it?
`A. It is the reference commonly referred to as
` Pinsley.
`Q. And if I refer to it as Pinsley, you'll
` understand I'm speaking about this exhibit?
`A. I do, yes.
`Q. Pinsley was one of the references you
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` UWE R. KORTSHAGEN, Ph.D.
` considered in connection with the prepare of
` your supplemental declaration; is that right?
`A. That is correct, yes.
`Q. When is the last time you had a chance to
` review it?
`A. To review Pinsley?
`Q. Yes.
`A. Again, I believe that I reviewed the relevant
` parts of it or what I considered to be
` relevant to this proceeding over the weekend,
` and I have read it in -- read it in its
` entirety probably a few weeks ago.
`Q. Would you agree that Pinsley describes an
` electric discharge plasma in a flowing gas
` laser?
`A. I'm hesitating because the term flowing gas
` laser is -- yeah, can you repeat your
` question? I'm sorry.
`Q. Sure. And you may wish to refer to column 1
` between lines 48 and 50. The question was
` would you agree that Pinsley describes an
` electric discharge plasma in a flowing gas
` laser?
`A. Aha. Yes, this is what it states here in
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` UWE R. KORTSHAGEN, Ph.D.
` column 1, yes.
`Q. I'd like to discuss the figure shown in
` Pinsley. There is only the one figure,
` right?
`A. That is correct, yes.
`Q. Just so we get some terminology correct, the
` element labeled 18 in the figure is the
` anode, correct?
`A. That is correct, yes.
`Q. And the element labeled 19 is the cathode,
` correct?
`A. That is correct, yes.
`Q. Elements 24 and 26 are magnetic pole pieces;
` is that right?
`A. That is correct.
`Q. And those magnetic pole pieces create a
` magnetic field in the direction indicated by
` the vector B, correct?
`A. Yeah, the magnetic pole pieces 24 and 26
` create a magnetic field that in some portions
` of the space between the anode and the
` cathode will be pointing into the direction
` as shown by the magnetic field vector 28, in
` other portions it'll have slightly different
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` UWE R. KORTSHAGEN, Ph.D.
` direction.
`Q. And if we refer to column 2, lines about 37
` through 39, Pinsley in fact indicates that,
` "The magnetic field exists from the top to
` bottom as viewed in the figure and as
` indicated by the vector 28," right?
`A. What you just read is the precise reading of
` what Pinsley states in column 2, lines 37 to
` 39, that is correct.
`Q. If we look back at the figure, the movement
` of the electrons between the cathode and the
` anode create a current vector indicated by J;
` is that right?
`A. Yes, that is correct.
`Q. And the interaction between the current and
` the magnetic field results in the force F
` exerted on the electrons, correct?
`A. That is generally correct. But as I already
` pointed out, because the magnetic field is
` not perfectly straight and in various
` portions of the space between the anode and
` the cathode, the magnetic field vector may
` actually point in slightly different
` directions. There will also be a slightly
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` UWE R. KORTSHAGEN, Ph.D.
` different direction to the vector F in
` different portions of the space between the
` anode and the cathode.
`Q. The vector J might also point in slightly
` different directions than what is indicated
` in the illustration, right?
`A. In general, I believe that is correct, but I
` would expect the vector J to show less of the
` variation than the vector B for the magnetic
` fields.
`Q. Why?
`A. This is a very valid question and maybe my
` answer was biassed by my view of the
` dimensions which are shown here in Figure 1
` which show -- which suggest a larger distance
` between the anode 18 and the cathode 19 as
` compared to the distance between the two pole
` pieces 24 and 26, and based on these
` distances my assumption was that the electric
` field and with it the direction of the vector
` J would show less of a curvature.
` But my understanding is that no
` dimensions are actually given and that other
` dimensions may be used, so maybe I shouldn't
`
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` even say that I expect less of a variation in
` the vector J than in the vector B.
`Q. And you didn't perform any experiments or
` simulations concerning the apparatus shown in
` Pinsley in connection with the preparation of
` your declaration, did you?
` MR. TENNANT: Objection to form.
` THE WITNESS: No, I did not. And
` I do believe that one of ordinary skill would
` understand some basic physical principles
` such as the shape of the magnetic fields
` between two pole pieces that actual
` experiments or simulations are not really
` required.
`BY MR. FAHMI:
`Q. Considering for a moment the motion of the
` electrons in the arrangement shown in the
` figure of Pinsley, is it correct that the
` electrons will move in a direction that is
` perpendicular to both the electric field and
` the magnetic field?
` MR. TENNANT: Objection to form.
` THE WITNESS: It is correct that
` one part of their motion will be in a
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` direction as you describe, namely,
` perpendicular to the magnetic and electric
` fields.
`BY MR. FAHMI:
`Q. And there may also be a spiral trajectory
` superimposed on that motion, right?
` MR. TENNANT: Objection to form.
` THE WITNESS: I actually would
` describe it differently. I would describe it
` as that there is a spiral motion, as you
` called it, or a gyro motion, and superimposed
` to that is the motion of electrons in a
` direction perpendicular to the electric and
` magnetic fields.
`BY MR. FAHMI:
`Q. Considering the box 12 that's shown in the
` illustration that's labeled source of lasing
` and other gases, do you see that?
`A. Uh-huh.
`Q. If I call that a feed gas, will you
` understand what I'm referring to?
` MR. TENNANT: Objection to form.
` THE WITNESS: Yes, I think I
` understand what you're referring to.
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`BY MR. FAHMI:
`Q. Are there any ground state atoms in that feed
` gas?
`A. Commonly, the majority of atoms in a feed gas
` will likely be in the ground state.
`Q. So what, if anything, would be the effect of
` the magnetic field in Pinsley on those ground
` state atoms?
`A. Are you asking the question whether there is
` an effect on the ground state atoms by the
` magnetic field in the absence of a discharge?
`Q. We could start there.
`A. Okay.
`Q. So let's say in the absence of a discharge,
` that would presume the absence of an electric
` field, right?
`A. It would presume the absence of a current
` that could still be an electric field too
` weak to actually maintain or ignite a plasma.
`Q. Okay. So under those conditions, what if
` anything would be the effect of the magnetic
` field on the ground state atoms coming from
` the source 12?
`A. I'm sorry, I'm thinking on a tangent here,
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` UWE R. KORTSHAGEN, Ph.D.
` because part of my answer is that there is no
` effect on the ground state atoms that would
` in any way affect their motion. And I'm
` saying I'm thinking on a tangent because you
` could imagine a gas with ground state atoms
` which have some kind of a magnetic moment,
` but I don't think that this is what you're
` referring to, right?
`Q. I'm sorry, what do you mean by a magnetic
` moment?
`A. Well, I mean some kind of magnetic moment --
` yeah, I mean, I cannot think of any kind of
` gas which would have something like this. A
` gas like argon, helium would not feel any
` effect by the magnetic field.
`Q. So now let's consider the case where there is
` a current, and it's still true that ground
` state atoms would exist from the source 12;
` is that right?
`A. That is correct, yes.
`Q. And in the case where there is a current, the
` plasma would exist between the anode and the
` cathode, correct?
`A. Yeah, roughly between the anode and the
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` UWE R. KORTSHAGEN, Ph.D.
` cathode. Yes, that is correct.
`Q. And there may still be ground state atoms
` present in that situation, correct?
`A. There will certainly be some ground state
` atoms present in that situation, that is
` correct, yes.
`Q. So considering that situation, what if
` anything would be the effect of the magnetic
` field on the ground state atoms?
`A. So I believe you can actually distinguish
` between a direct effect and an indirect
` effect.
` Direct effect in the sense that will the
` ground state atoms feel any kind of force due
` to the magnetic fields, the answer is still
` no, that they will not do that.
` Indirect effect in the sense that the
` magnetic field traps electrons and raises the
` electron density and thus leads to a higher
` probability of the grouped state atoms being
` excited and transformed into excited state
` atoms or metastable atoms, that indirect
` effect is there in the presence of a plasma.
`Q. So considering only the ground state atoms
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` UWE R. KORTSHAGEN, Ph.D.
` and not the excited atoms or the metastable
` atoms that may or may not be produced,
` considering only the ground state atoms, is
` it correct that the magnetic field has no
` effect whether or not a current is present?
` MR. TENNANT: Objection to form,
` relevance.
` THE WITNESS: I actually believe
` that this is not correct.
`BY MR. FAHMI:
`Q. So what, if anything, is the effect of the
` magnetic field on the ground state atoms?
`A. It is my opinion that the magnetic field, by
` trapping electrons, will increase the density
` of electrons and the plasma, and by
` increasing the density of electrons and the
` plasma, ground state atoms will experience
` collisions with electrons at a larger rate.
`Q. But you're not suggesting that there will be
` no more ground state atoms in that situation,
` right?
` MR. TENNANT: Objection to form.
` THE WITNESS: No, this is not what
` I'm suggesting. I believe there will be
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` UWE R. KORTSHAGEN, Ph.D.
` atoms in the ground state.
`BY MR. FAHMI:
`Q. So considering those atoms that remain in the
` ground state, is it correct that regardless
` of whether a current is present in this
` arrangement shown by Pinsley, the magnetic
` field will have no effect on those ground
` state atoms?
` MR. TENNANT: Objection to form.
` THE WITNESS: I actually believe
` that in any kind of realistic situation there
` will be very few ground state atoms that will
` pass through the space between the anode and
` the cathode without experiencing some type of
` a collision with some of the plasma electrons
` and, as such, the vast majority of ground
` state atoms will feel that there is an
` increased density of plasma electrons through
` the presence of the magnetic field.
` There may be, I would estimate, a
` minority of ground state atoms that may pass
` in the space between the anode and the
` cathode without any collisions with electrons
` and those ground state -- those ground state
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` UWE R. KORTSHAGEN, Ph.D.
` atoms would in fact not feel any effect by
` the magnetic field.
`BY MR. FAHMI:
`Q. And for those minority of ground state atoms
` that do not feel any effect by the magnetic
` field, they would continue in the direction
` shown by the flow arrow 14; is that right?
`A. That is correct, yes.
`Q. I'm now going to hand you what's been
` previously marked as Exhibit 1206.
` (Hands document.)
`A. Thank you.
`Q. Do you recognize this exhibit?
`A. I do.
`Q. What is it?
`A. It is the reference commonly referred to as
` Angelbeck.
`Q. And if I refer to it as Angelbeck, you'll
` understand I'm speaking about this exhibit?
`A. I will.
`Q. When is the last time you had an opportunity
` to review the Angelbeck exhibit?
`A. Again, in its entirety, probably a few weeks
` ago. Reading what I think are the relevant
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` passages, just over the weekend.
`Q. Angelbeck is one of the references you
` considered in connection with the preparation
` of your supplemental declaration; is that
` right?
`A. That is correct, yes.
`Q. And referring to column 1, lines 61 and 62,
` Angelbeck indicates that one of the objects
` of this patent is a transverse magnetic field
` for controlling a gas laser; is that right?
`A. That is correct, yes.
`Q. And if we look at column 1, approximately
` lines 36 to 38, Angelbeck indicates that the
` application of a transverse magnetic field to
` a discharge gas laser increases the electron
` temperature; is that right?
` MR. TENNANT: Objection to form.
` THE WITNESS: It is correct that
` the passage starting at -- in column 1
` starting at line 36 indicates that the
` transverse magnetic field applied to a DC
` discharged gas laser increases the electron
` temperature and, hence, the efficiency of
` excitation.
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`BY MR. FAHMI:
`Q. And you would agree with that statement, I
` assume, correct?
`A. I do agree with that statement, correct.
`Q. If we refer to the illustrations Figures 1
` and 2 in Angelbeck, what is the direction of
` current flow in Figure 1?
`A. Figure 1, the direction of current flow is
` from the anode which is labeled 18 to the
` cathode which is labeled 20, and specifically
` it would be parallel to the axis of the tube
` 10.
`Q. And elements 24 and 26 are indicated as
` magnetic pole pieces; is that right?
`A. That is correct, yes.
`Q. And it's these magnetic pole pieces that
` create the transverse magnetic field in the
` direction indicated by the arrows B; is that
` right?
`A. That is correct. So are you referring to
` Figure 1 or Figure 2?
`Q. Well, let's start with Figure 1.
`A. Okay. Good.
`Q. So in Figure 1 the pole pieces 24 and 26
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` create a transverse magnetic field indicated
` by the arrows B; is that right?
`A. That is correct. And I just, for
` completeness, would like to add that I
` believe the magnetic field arrows B in
` Figure 1 are somewhat idealized, because the
` magnetic field, in particular, going towards
` the end of the pole pieces, will not be
` perfectly straight but will show some
` curvature.
`Q. And just as in the case with Pinsley, the
` electric field will not be perfectly straight
` between the anode and the cathode, correct?
` MR. TENNANT: Objection to
` foundation.
` THE WITNESS: Yeah, I mean, given
` the configuration here in Figure 1, the
` electric field will not be perfectly
` straight, I agree with that.
`BY MR. FAHMI:
`Q. Now, within the tube shown in Figure 1 there
` is a gas, correct?
`A. Yes, that is correct.
`Q. The ends of the tube are closed so the gas is
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` not flowing, right?
`A. In this particular configuration shown in
` Figure 1 the gas is not flowing, that is
` correct.
`Q. Are there any ground state atoms in that gas?
` MR. TENNANT: Objection to form.
` THE WITNESS: There will certainly
` be ground state atoms in that gas.
`BY MR. FAHMI:
`Q. In the absence of any current flow, what, if
` anything, would be the effect of the magnetic
` field on those ground state atoms?
` MR. TENNANT: Objection to form.
` THE WITNESS: In the absence of a
` current flow, as we discussed in Pinsley, I
` believe there is no effect of the magnetic
` field on the ground state atoms.
`BY MR. FAHMI:
`Q. What about when a current flow exists, what,
` if anything, would be the effect of the
` magnetic field on the ground state atoms?
` MR. TENNANT: Objection to form.
` THE WITNESS: Very similar to what
` we discussed in Pinsley, I believe that the
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` magnetic field in Angelbeck traps electrons
` and thus enhances the density of electrons
` and the excite -- and, thus, it'll enhance
` the excitation of ground state atoms so
` indirectly ground state at
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