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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 7,147,759 B2
`--------------------------------------------
` IPR Case Nos. IPR2014-00781, 00782,
` 01083, 01086, 01087
`--------------------------------------------
`
` 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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`TSG Reporting - Worldwide 877-702-9580
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` OVERZET - 5/8/15
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`Page 2
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` May 8, 2015
` 9:08 a.m.
`
` Deposition of LAWRENCE J. OVERZET, PH.D.,
`held at the offices of Baker Botts, 2001 Ross
`Avenue, Dallas, Texas, before Susan S. Klinger,
`a Registered Merit Reporter and Certified
`Realtime Reporter of the State of Texas.
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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
`the tape labeled number 1 in the video
`deposition of Dr. Overzet in the matter of
`Fujitsu versus Zond in the United States
`Patent and Trademark Office, Case No.
`IPR2014-000781, 782, 1083, 1086, 1087,
`Patent 7,147,756 B2.
` This deposition is being held --
` MR. TENNANT: 759.
` VIDEOGRAPHER: 759. I'm sorry.
`Correction. Patent Number 7,147,759 B2.
` This deposition is being held at
`Baker Botts, 2001 Ross Avenue, Dallas,
`Texas, on May 8th, 2015. The approximate
`time is 9:09 a.m.
` My name is Jay Wiggins. I'm a legal
`video specialist representing TSG
`Reporting, headquartered in -- at 747 Third
`Avenue, New York, New York. The court
`reporter is Susan Klinger in association --
`in association with TSG Reporting.
` Will counsel please introduce
`yourselves.
` DR. GONSALVES: My name is
`
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` OVERZET - 5/8/15
` Dr. Gregory Gonsalves. I'm the attorney
` for the patent owner, Zond.
` MR. TENNANT: David Tennant with
` White & Case. I'm the attorney for
` GlobalFoundries.
` VIDEOGRAPHER: Will the court
` reporter please swear in the witness.
` LAWRENCE OVERZET, PH.D.,
`having been first duly sworn, testified as
`follows:
` MR. TENNANT: Just a clarification
` on the record, all my objections will be on
` behalf of all petitioners in the
` proceedings. Hopefully, I won't have to
` make any objections.
` EXAMINATION
`BY DR. GONSALVES:
` Q. Dr. Overzet, you were deposed
`yesterday; is that correct?
` A. That's correct.
` Q. And this -- that involved an IPR
`proceeding involved Zond, also; is that
`correct?
` A. That's correct.
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` OVERZET - 5/8/15
` Q. Prior to then, had you been deposed
`in any other IPRs?
` A. No.
` Q. Have you served as an expert in any
`other IPRs, besides the Zond IPRs?
` A. No.
` Q. Have you served -- do you know what
`a covered business method review is?
` A. No, I do not.
` Q. Okay. A covered business method
`review is similar to an IPR, but it's limited
`to those types of patents that are considered
`to be business methods by the Patent Office.
` So in light of that description, do
`you recall serving as an expert in any covered
`business method proceedings at the Patent
`Office?
` A. No.
` Q. Have you ever served as an expert in
`patent cases pending in a district court?
` A. You mean other than the Zond case
`or --
` Q. Correct.
` A. I have not.
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` OVERZET - 5/8/15
` Q. Okay. Well, on the -- you've -- I'm
`sure you have gone over this yesterday, but the
`proceeding is, is that I will ask you
`questions. And that if you don't understand
`the question, please let me know, and I'll try
`to clarify it for you.
` A. Uh-huh.
` Q. Is that okay?
` A. Yes. Yes.
` Q. And -- but if you do understand --
`if you do answer a question, I'll take that to
`mean that you do understand it; is that fair?
` A. Okay.
` DR. GONSALVES: And all the exhibits
` that I will be using today don't need to be
` marked because they're already of record in
` the case.
` Q. Dr. Overzet, I'm going to be handing
`you a document entitled "Ionization relaxation
`in a plasma produced by a pulsed inner gas
`discharge," by Kudryavtsev.
` Do you recognize this document,
`Dr. Overzet?
` A. Yes.
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` OVERZET - 5/8/15
` Q. Is it your understanding that
`Kudryavtsev discloses a -- certain experiments
`that were performed?
` A. Kudryavtsev discloses primarily a
`model as described in his abstract. He also
`discloses some experiments that were performed
`to, as he puts it, verify the model, as well.
` Q. To perform the experiments, did
`Kudryavtsev use a device including electrodes
`and a cylindrical tube of diameter 2.5
`centimeters?
` MR. TENNANT: Objection, form.
` A. Kudryavtsev writes on page 32 in the
`right column, the fifth paragraph, the center
`of the paragraph: "The discharge occurred
`inside a cylindrical tube of diameter 2R equals
`2.5 centimeters."
` Q. And the other part of my question is
`whether -- whether the device disclosed in
`Kudryavtsev included electrodes.
` A. I'm not seeing the place in
`Kudryavtsev where he discloses this, but this
`is my understanding.
` Q. Is the distance between the
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` OVERZET - 5/8/15
`electrodes in Kudryavtsev 52 centimeters?
` A. On that same page, Kudryavtsev does
`disclose a distance -- ah, between the
`electrodes, there is exactly where it was for
`the prior question -- of 52 centimeters.
` But I would emphasize that this is
`not his primary disclosure in the model or in
`this paper, together with Skrebov, but rather,
`that the primary disclosure is his model.
` Q. Kudryavtsev makes no mention of a
`magnet; is that correct?
` MR. TENNANT: Objection, form.
` A. Kudryavtsev describes his model as
`being applicable in a variety of situations.
`So, for example, in the last paragraph, he
`writes: "Since the effects studied in this
`work are characteristic of ionization whenever
`a field is suddenly applied to a weakly-ionized
`gas."
` Q. Are you finished?
` A. Yes, yes.
` Q. My question, though, was directed to
`whether Kudryavtsev mentions a magnet in -- in
`his document.
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` OVERZET - 5/8/15
` A. Relating to the verification
`experiments?
` Q. Relating to anything, does he make
`any mention of using a magnet in his -- in the
`device that's disclosed in Kudryavtsev?
` MR. TENNANT: Objection, form.
` A. For the experiments that Kudryavtsev
`used to verify his much more widely applicable
`model, he did not disclose the use of a magnet.
` Q. Can you turn to Equation 8, which is
`at page 32 of Kudryavtsev. What does the
`capital N represent?
` A. My understanding is that the
`capital N is, in fact, described in Equations 5
`and 6.
` Q. What does capital N represent?
` A. In Equation 6, on page 31, in the
`right-hand column, Kudryavtsev and Skrebov
`disclose N equals n sub e by n sub e 0.
` Q. Could you tell me what capital N
`means to you, or should we ask about --
`let's -- let's stop the question there.
` Could you tell me what the capital N
`represents in words, according to your opinion?
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` OVERZET - 5/8/15
` A. Just above Equation 5, Kudryavtsev
`and Skrebov note that -- that they have placed
`Equations 1 and 2 -- although I may need to
`backtrack on that slightly.
` Yeah. So above Equation 5,
`Kudryavtsev and Skrebov indicate that: "In
`dimensionless variables, the equations for the
`ionization kinetics take the form shown in
`Equation 5."
` So N is a dimensionless variable
`above -- just below Equations 1 and 2 in that
`paragraph, he says: Here n1, n2, and ne are
`the atomic densities in the ground and first
`excited states and the electron density
`respectively. So I take n sub e in the capital
`N variable to be the electron density.
` N sub e 0 -- I want to make sure I
`find in the text again, so gave me another
`moment, please. Ah. N sub e 0 is defined
`by -- implicitly in Equation 6 itself, where he
`writes that capital N, taken at tau equals 0 is
`equal to 1. Therefore, capital N taken at tau
`equal to 0 tells us that n sub e 0 is the value
`of n sub e when tau is equal to 0.
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` OVERZET - 5/8/15
` Q. And tau is equal to 0, does that
`represent the initial condition?
` MR. TENNANT: Objection, form.
` A. I'm not finding the place where he
`defines tau equals 0, but it's my recollection
`that tau equals 0 is a starting condition.
` Q. So would n subscript e 0 --
` A. Ah.
` Q. -- represent the electronic --
`electron density at the starting condition that
`you mentioned?
` A. Yes. And I've just now found it.
`It's also in Equation 6. Perhaps it's a little
`bit of nerves again here.
` Tau is defined as t times n1 times
`k12. So in tau is equal to 0, since n1, k12
`cannot be 0, it must be the time T equals 0.
` Q. Okay. Kudryavtsev makes no
`mention -- strike the question. Let me start
`over.
` Kudryavtsev's device does not have a
`magnetic field; is that correct?
` MR. TENNANT: Objection, form.
` A. Are you referring to the device that
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` OVERZET - 5/8/15
`he used to verify his model?
` Q. Yes.
` A. It's my understanding that he did
`not utilize a magnetic field, other than the
`earth's magnetic field, in that device.
` Q. And Kudryavtsev's device does not
`perform sputtering; is that correct?
` A. Are you referring to the device he
`used for verifying his generally applicable
`model?
` Q. Yes.
` A. Yes. And the device he used for
`verifying his more generally applicable model
`is not a device used for sputtering.
` Q. Now, you referred in your answer to
`the device that he used for verifying his
`model. Are there any other devices, other than
`that one you mentioned, disclosed in the
`Kudryavtsev document?
` A. I believe the answer is yes.
` Q. And where do you see this other
`device?
` A. Kudryavtsev, on page 34, described
`experiments in references 18 and 19.
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` OVERZET - 5/8/15
` Q. In what column to page 34 are you,
`so I can get to the right one?
` A. I'm sorry. The right-hand column,
`the second paragraph, the first sentence.
` Q. So in that paragraph that you
`pointed me, Kudryavtsev is referring to a
`device that was disclosed in other papers; is
`that correct?
` A. Yes, which he used for verifying his
`more widely applicable model.
` Q. Besides the two devices that you've
`just identified, are there any other devices
`disclosed in the Kudryavtsev paper?
` A. I believe that since there are two
`references, there may, in fact, be at least
`three devices and not two, just two.
` Q. What device --
` A. In addition --
` Q. Go ahead. I'm sorry.
` A. -- on device per reference.
` Q. That's what I was going to ask. Is
`that your understanding?
` A. I have not gone into the details of
`those references, but my understanding from --
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` OVERZET - 5/8/15
`only comes from Kudryavtsev and Skrebov. Have
`I answered your question?
` Q. I think so. Can you take a look at
`page 32?
` A. I'm there.
` Q. Equation 8, the one that we were
`just referring to?
` A. Yes.
` Q. Do you see underneath that there is
`a capital A?
` A. Yes.
` Q. What does capital A represent?
` A. Kudryavtsev and Skrebov describe
`that for us underneath Equation 10. He says,
`beginning just before the equation: "Where A
`is given by -- Equation 10 -- and describes the
`relative contribution from the various
`processes in (5) for small times."
` Q. In your answer -- in -- in the text,
`it refers to "relative contribution." What
`does Kudryavtsev mean by relative contribution?
` A. In Equation 10, do you see that
`there are multiple terms?
` Q. Yes.
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` OVERZET - 5/8/15
` A. Some terms may be larger than
`others.
` Q. Does Kudryavtsev disclose that
`ionization develops when capital A is greater
`than 0?
` MR. TENNANT: Objection, form.
` A. I believe you may be referring to
`the paragraph immediately following
`Equation 10, where Kudryavtsev and Skrebov
`write: The conditions for ne to increase with
`time are that ionization should always develop
`eventually if A is greater than 0.
` Q. I wasn't referring to any passage in
`particular. I was just asking for your opinion
`as to whether Kudryavtsev discloses that
`ionization occurs when A -- capital A is
`greater than 0.
` MR. TENNANT: Objection, asked and
` answered. Form.
` A. It -- my understanding is that
`Kudryavtsev does disclose that ionization
`occurs independent of A.
` Q. And why do you -- let me start over.
` What brings you to that conclusion?
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` OVERZET - 5/8/15
` A. In Kudryavtsev's equations, there is
`an ionization term -- actually, ionization
`terms.
` Q. Which equation were you referring to
`in your answer?
` A. Either Equations 5 or Equations 1
`and 2.
` Q. Okay. So let's take Equation 1.
`What are the ionization terms in Equation 1?
` A. Kudryavtsev identifies those terms
`for us beginning at the bottom of page 30 and
`continuing at the top of page 31. He
`identifies that beta sub 1e and beta sub 2e are
`the rate coefficients for direct ionization
`from the ground state to the first excited
`and -- to the first excited level.
` Q. Okay. When you mentioned that you
`understood that Kudryavtsev discloses
`ionization -- ionization occurs independent of
`capital A, did you mean that there are certain
`equations in Kudryavtsev that don't use the
`term capital A?
` A. No, that is not what I meant.
` Q. Okay. What did you mean?
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` A. I meant that in this paper,
`Kudryavtsev describes ionization occurring when
`A is greater than 0 and when A is less than 0.
` Q. Can you turn your attention to
`page 32, right column, third paragraph?
` A. Am I on 32 already? Yes. One, two,
`three. Uh-huh.
` Q. And do you see first phrase of that
`paragraph that reads: "The explosive increase
`in n sub e(t) is most apparent when A is
`greater than 0?
` A. I do.
` Q. What does that sentence mean to you?
` A. Excuse me. To me, that sentence is
`clear to one of ordinary skill in the art that
`the electron density increase is most easily
`seen when A is greater than 0.
` Q. Now, can you keep that sentence in
`mind and turn to the previous page and look at
`Figure 1. Now, the paragraph that you just
`read from referred to the explosive increase in
`n sub e(t).
` A. Uh-huh.
` Q. Does that phrase correspond with the
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`fast stage that's depicted in Figure 1b?
` MR. TENNANT: Objection, form.
` A. I would respond that the explosive
`increase in n sub e of (t) is consistent with
`Figure "b" -- or Figure 1b.
` Q. Do the -- does the width of the
`arrows in Figure 1 correspond to the magnitude
`of the electron flux?
` MR. TENNANT: Objection, form,
` relevance.
` A. The caption of Figure 1 states:
`"Diagram showing the relative sizes of the
`electron fluxes in terms of the atomic energy
`levels." The width -- and then later: "The
`width of the arrows indicates the magnitude of
`the electron flux."
` Q. So in light of that passage that you
`just read, if two arrows in Figure 1 are shown
`as having the same width, does that mean that
`the magnitude of the corresponding electron
`fluxes are about equal?
` MR. TENNANT: Objection, form,
` relevance.
` A. I would take it to mean that the
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`electron fluxes are approximately equal.
` Q. What is electron flux?
` A. In Figure 1b this would be described
`as electrons moving from one energy level to
`another. In the case there is also, however,
`shown between -- no -- shown to the right of
`Figure 1b an arrow that's an identified in
`Figure 1b, which has a different meaning.
` Q. And the arrow that you just referred
`to in your answer, were -- were you referring
`to the -- to the arrow that's labeled tau
`subscript 1e?
` A. I don't see a tau --
` Q. What do you call --
` A. -- in Figure 1b.
` Q. What -- it looks a little like a tau
`to me, but it's not. But what would you call
`that symbol which --
` A. Could you please point to it for me?
` Q. Yeah. It's on the rightmost portion
`of the Figure 1b, and I'll also point to it.
` A. This one here?
` Q. Yes.
` A. That's a capital Gamma.
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` Q. Capital Gamma?
` A. So that would be Gamma sub 1e.
` Q. And what does capital Gamma sub 1e
`represent?
` A. My understanding, based on the text
`on page 31 at the top on the left-hand column,
`is that -- I'm sorry. That's a different
`symbol there, isn't it?
` My recollection -- and I may need to
`revisit this, but my recollection is that Gamma
`sub 1e represents direct ionization from
`State 1 to having a free electron.
` Q. Does Gamma sub 12 in Figure 1 of
`Kudryavtsev represent the flux of excited
`atoms?
` A. No, it does not.
` Q. What does it represent?
` A. Gamma sub 12 represents the flux of
`electrons from State 1 to State 2.
` Q. And is State 1 considered to be the
`ground state?
` A. On page 30, in the final paragraph,
`Kudryavtsev writes: "Here n1, n2, and n sub e
`are the atomic densities in the ground and
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`first excited states and the electron density
`respectively."
` So I would take 1 to mean the ground
`state.
` Q. Would you also understand n
`subscript 2 to be the atomic density in the
`first excited state?
` A. That is what I believe he says in
`that same sentence.
` Q. Okay. And so turning back to
`Figure 1 on the next page --
` A. Uh-huh.
` Q. -- would your understanding of Gamma
`subscript 12 represent the flux of the atoms
`going from the ground state to the excited
`state?
` MR. TENNANT: Objection, form.
` A. I believe I've already answered that
`question. It's the -- it's stated it's the
`flux of electrons going from Energy State 1 to
`Energy State 2.
` Q. Okay. Now, are the arrows -- strike
`the question. Let me start over.
` Is the width of the arrow
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`corresponding to Gamma subscript 12 in Figure
`1a the same as the width of the arrow
`corresponding to Gamma subscript 12 in Figure
`1b?
` MR. TENNANT: Objection, form,
` relevance.
` A. Figure 1 is a highly stylized
`representation of the processes that are
`ongoing in the plasma. As such, the visual
`representation in part "a" to one of ordinary
`skill in the art is not intended to relate to
`the visual in part "b" in the sense that one
`would measure the width of Gamma 12 arrow and
`compare it to Gamma 12 in "b." It simply
`indicates the relative contributions at a given
`state in time, or a given stage.
` Q. Does Kudryavtsev teach a model that
`was developed for the initial stage of
`ionization relaxation?
` MR. TENNANT: Objection, form,
` relevance.
` A. My understanding is that the
`abstract addresses this question, where
`Kudryavtsev writes: "A model is developed for
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`the initial stage of ionization relaxation."
` Q. And what does the phrase "initial
`stage of ionization relaxation" mean to a
`person of ordinary skill in the art?
` A. I would assert that Kudryavtsev
`answers this question, as well, in the second
`paragraph of his publication. Kudryavtsev and
`Skrebov write: "In this paper we consider the
`initial stage of ionization relaxation when the
`ionization n sub e to n1 increases."
` Q. Earlier I believe you had testified
`that Kudryavtsev discloses a model; is that
`correct?
` A. That's what he says in his abstract.
` Q. Now, is the model that Kudryavtsev
`discloses -- would you consider it to be an
`empirical model?
` MR. TENNANT: Objection, form.
` A. Could you please define for me what
`it is that you mean by "an empirical model"?
` Q. Well, have you -- have you heard the
`term "empirical model" before today?
` A. Uh-huh.
` Q. What does it mean to you when you
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`hear it?
` A. A model that is developed from
`experiment.
` Q. So I'll take that definition because
`it's consistent with my understanding.
` So in light of that definition,
`would you consider the model that's disclosed
`in Kudryavtsev an empirical model?
` A. This question is beyond what I was
`asked to address in my declaration. The nature
`of the model is very general, but I would not
`consider it to be limited to an empirical
`model.
` Q. What other types of models are there
`besides empirical models?
` A. There are several.
` Q. What are they?
` A. There are analytical models. There
`are numerical models. There are -- excuse
`me -- what one would call fundamental models of
`various sorts.
` Q. Of the three -- of the three types
`of models that you just referenced in your
`answer, are any of -- do you see any of those
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`types of models disclosed in Kudryavtsev?
` A. I would put this -- I would say, if
`I'm putting a label on Kudryavtsev and
`Skrebov's model, that it is a fundamental model
`of one sort.
` Q. Can you turn to page 33, please, of
`Kudryavtsev? In your opinion, does Figure 5
`display a graph of the experimental results
`that were obtained using Kudryavtsev's device?
` A. I do not believe it to be a graph of
`experimental results from Kudryavtsev's device.
` Q. What do you believe it to be?
` A. Kudryavtsev describes his Figure 5
`on page 34 in the left-hand column. He says,
`in the sixth paragraph, in the center:
`"Figure 5 shows curves giving the time
`dependence of n sub e of (r) calculated from
`(9b)."
` To me, the keyword in that sentence
`is "calculated."
` Q. And turning to (9b) on page 32, what
`does (9b) represent to you?
` MR. TENNANT: Objection, form,
` relevance.
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` A. I was not asked, as part of my
`declaration, to -- to teach on the meaning of
`(9b). However, given that (9b) has, on the
`left-hand side of the equation, the variable --
`the dimensionless variable tau, I would say it
`discloses tau.
` Q. And what does tau represent in
`Equation (9b)?
` A. Tau is disclosed as we discussed
`earlier in Equation 6. Equation 6 says that
`tau is equal to t times n1 times k12.
` Q. Would you consider Equation (9b) to
`be a model?
` MR. TENNANT: Objection, form,
` relevance.
` A. It would be my understanding, and I
`believe it would be the understanding of one of
`ordinary skill in the art, that to limit
`Kudryavtsev's paper to a -- and model to a
`single equation would be to do violence to this
`paper.
` Q. Okay. I'm not saying it was the
`only thing disclosed in the paper.
` My question is whether (9b) is one
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`of the models that's disclosed in Kudryavtsev.
` MR. TENNANT: Same objections.
` A. I would disagree with that.
` Q. You don't see equation (9b) as a
`model?
` MR. TENNANT: Same objections.
` A. I would say that Equation (9b) is an
`equation.
` Q. Does Figure 5 shown on page 33 have
`three dimensions?
` A. I do count three dimensions, each
`different from the other.
` Q. Does the horizontal --
` A. Excuse me.
` Q. Does the horizontal axis of Figure 5
`represent the normalized radius of
`Kudryavtsev's cylinder?
` A. I would disagree with that.
` Q. What do you feel the horizontal axis
`of Figure 5 represents?
` A. Normalized radius.
` Q. A normalized radius of what type of
`device?
` A. Kudryavtsev's model is widely
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`applicable, and so it could be many different
`devices.
` Q. What type of device could it be?
` A. There are many types of devices that
`it could be.
` Q. Well, it would have to be a type of
`device that has a radius; correct?
` A. Correct.
` Q. Okay. For example --
` A. Normalized.
` Q. For example, a rectangular prism
`doesn't have a radius; correct?
` MR. TENNANT: Objection, form.
` A. I'm sorry. Say that again.
` Q. For example, a rectangular prism
`doesn't have a radius; correct?
` MR. TENNANT: Same objection.
` A. Since Kudryavtsev has a model that
`is widely applicable, he could, and one of
`ordinary skill in the art -- let me rephrase
`that.
` He could choose to apply his model
`in various volumes. His model would not simply
`be limited to things having a simple radius,
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`cylindrical or spherical.
` Q. But my question was with respect to
`Figure 5.
` A. Figure 5 discloses one kind of an
`environment that has a radius.
` Q. So Figure 5 would be limited to only
`those types of shapes that have a radius; is
`that correct?
` MR. TENNANT: Objection, form.
` Asked and answered.
` A. My understanding is that Figure 5
`would be most readily applied to that kind of a
`system, but still could have application
`outside.
` Q. Does the vertical axis of Figure 5
`represent the density of electrons?
` A. The vertical axis is a normalized
`variable. Kudryavtsev and Skrebov write
`that -- that normalized variable is the
`electron density n sub e as a function of
`radius divided by N sub e 0.
` Q. Is the electron density -- let me
`start over.
` Does the electron density also
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`correspond to the ion density?
` MR. TENNANT: Objection, form,
` relevance.
` A. So in this case, my understanding is
`that you're asking a basic plasma science
`background question that also is not part of my
`declaration.
` My understanding is that in some
`circumstances, the electron density and
`positive ion density can be substantially
`similar. In other cases, they can diverge.
` Q. Why would they diverge? Let me
`rephrase that.
` You had mentioned in some cases that
`the electron density and positive ion density
`would diverge. What cases were you referring
`to?
` MR. TENNANT: Objection, relevance.
` A. There is a field in plasma science
`wherein one studies what are called nonneutral
`plasmas.
` Q. Does the axis shown as going into
`the page in Figure 5 represent the amount of
`time that a pulse is applied?
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` A. I believe it would have been helpful
`if I had brought my magnifying gla
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