`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Exhibit 2011
`Exhibit 2011
`
`

`

`1
`
`2
`3
`
`4
`
`5
`
`6
`
`7
`8
`
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`
`25
`
`Page 1
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD.
`AND TSMC NORTH AMERICA CORP., Case Nos.
` IPR2014-00818
` Petitioners, IPR2014-00819
` IPR2014-00821
`-vs- IPR2014-00827
` IPR2014-01098
`ZOND, LLC,
` Patent Owner.
`________________________________
`
` VIDEOTAPED DEPOSITION of DR. UWE KORTSHAGEN
` Minneapolis, Minnesota
` December 4th, 2014
`
`Reported by:
`Amy L. Larson, RPR
`Job No. 87858
`
`TSG Reporting - Worldwide 877-702-9580
`
`

`

`Page 2
`
`Page 3
`
`Page 5
`
`APPEARANCES: (CONT'D.)
` WHITE & CASE
` 701 Thirteenth Street, N.W.
` Washington, D.C. 20005
` By: David Tennant, Esq.
` By: Brett Rismiller, Esq.
` For: Global Foundries
`
` O'MELVENY & MYERS
` 400 South Hope Street
` Los Angeles, California 90071
` By: Vincent Zhou, Esq. (By telephone)
` For: Advanced Micro Devices
`
` FOLEY & LARDNER
` 321 North Clark Street
` Chicago, Illinois 60654
` By: Michael Houston, Esq. (By telephone)
` For: Renesas Electronics Corporation and
` Renesas Electronics America, Inc.
`
` BAKER BOTTS
` One Shell Plaza
` 910 Louisiana Street
` Houston, Texas 77002
` By: Michael Silliman, Esq.
` For: Toshiba
`
` ALSO PRESENT: Dean Hibben, Videographer
`
`INDEX: (CONT'D.)
`PREVIOUSLY MARKED EXHIBITS:
`Exhibit TSMC 1216
`U.S. Patent 6,306,265 B1
`No Bates
`Exhibit TSMC 1221
`U.S. Patent 5,247,531
`No Bates
`Exhibit TSMC 1222
`European Patent Application
`No Bates
`Exhibit TSMC 1302
`Kortshagen Declaration - '759 Patent
`No Bates
`Exhibit
`Paper 13 - No Bates
`
`1
`2
`3
`4
`
`56789
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`APPEARANCES:
` RADULESCU
` 350 Fifth Avenue
` New York, New York 10118
` By: Etai Lahav, Esq.
` Maria Granovsky, Esq.
` For: Zond, LLC
`
` GONSALVES LAW FIRM
` 2216 Beacon Lane
` Falls Church, Virginia 22043
` By: Gregory Gonsalves, Esq.
` For: Zond, LLC
`
` DUANE MORRIS
` 100 High Street
` Boston, Massachusetts 02110
` By: Anthony Fitzpatrick, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
` HAYNES AND BOONE
` 2323 Victory Avenue
` Dallas, Texas 75219
` By: David McCombs, Esq.
` By: Gregory Huh, Esq.
` For: Taiwan Semiconductor Manufacturing
` Company Limited and
` TSMC North America
`
` ///
`
`Page 4
`
`1
`2
`3
`4
`
`56
`
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`INDEX:
`2
`EXAMINATION BY: PAGE
`3 Mr. Lahav....................................8
`4
`EXHIBITS MARKED FOR IDENTIFICATION:
`5
`Exhibit 2004...............................112
`Cathodic Arcs
`6
`No Bates
`7
`PREVIOUSLY MARKED EXHIBITS:
`8
`Exhibit TSMC 1001
`U.S. Patent No. 6,853,142 B2
`9
`No Bates
`10
`Exhibit INTEL 1002
`Kortshagen Declaration - '759 Patent
`11
`No Bates
`12
`Exhibit TSMC 1003
`High-Current Low-Pressure Quasi-Stationary
`13
`Discharge in a Magnetic Field
`Experimental Research
`14
`No Bates
`15
`Exhibit TSMC 1004
`U.S. Patent No. 6,190,512 B1
`16
`No Bates
`17
`Exhibit TSMC 1201
`U.S. Patent No. 7,147,759 B2
`18
`No Bates
`19
`Exhibit TSMC 1202
`Kortshagen Declaration - '142 Patent
`20
`No Bates
`21
`Exhibit TSMC 1204
`Ionization Relaxation in a plasma produced
`22
`by a pulsed inert-gas discharge
`No Bates
`23
`24
`25
`
`Exhibit TSMC 1205
`U.S. Patent 6,413,382 B1
`No Bates
`
`TSG Reporting - Worldwide 877-702-9580
`
`2 (Pages 2 to 5)
`
`

`

`Page 6
`1
`THE VIDEOTAPED DEPOSITION OF DR. UWE KORTSHAGEN,
`2
`taken on this 4th day of December, 2014, at The
`3
`Commons Hotel, 615 Washington Avenue, S.E.,
`4 Minneapolis, Minnesota, commencing at
`5
`approximately 10:30 a.m.
`
`Page 7
`
`1
` DR. UWE KORTSHAGEN
`2
` Will counsel please introduce yourselves.
`3
` MR. LAHAV: Etai Lahav of
`4
`Radulescu, LLP, representing patent owner
`5
`Zond.
`6
` MS. GRANOVSKY: Maria Granovsky,
`7
`Radulescu, LLP, representing Zond.
`8
` MR. GONSALVES: Gregory Gonsalves
`9
`representing Zond.
`10
` MR. FITZPATRICK: Anthony
`11
`Fitzpatrick from Duane Morris, LLP, on behalf
`12
`of Taiwan Semiconductor Manufacturing Company
`13
`Limited and TSMC North America.
`14
` MR. TENNANT: David Tennant of
`15 White & Case, I'm here with my colleague
`16
`Brett Rismiller of White & Case, we are
`17
`representing Global Foundries U.S. Inc.,
`18
`Global Foundries Dresden Module One LLC & Co.
`19
`KG, Global Foundries Dresden Module Two LLC &
`20
`Co. KG.
`21
` MR. MCCOMBS: David McCombs
`22
`representing Taiwan Semiconductor
`23 Manufacturing Limited, TSMC North America and
`24
`Fujitsu.
`25
` MR. HUH: Gregory Huh from
`
` P R O C E E D I N G S
`
` THE VIDEOGRAPHER: This is video
` number 1 in the deposition of Dr. Uwe
` Kortshagen in the matter of Taiwan
` Semiconductor Manufacturing Company, Ltd.,
` et al., vs. Zond, LLC, in the United States
` Patent and Trademark Office before the Patent
` Trial and Appeal Board, numbers
` IPR2014-00818, 00819, 00821, 00827 and 01098.
` The deposition is being held at The
` Commons Hotel in Minneapolis, Minnesota on
` December 4th, 2014, at approximately
` 10:29 a.m. My name is Dean Hibben, I'm the
` legal video specialist from TSG Reporting
` Incorporated, headquartered at 747 Third
` Avenue, New York, New York. The court
` reporter is Amy Larson in association with
` TSG Reporting.
`
`67
`
`89
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Page 8
`
`Page 9
`
`1
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`5
`6
`7
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`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` DR. UWE KORTSHAGEN
` Haynes & Boone representing Taiwan
` Semiconductor Manufacturing Limited and
` North -- TSMC North America and Fujitsu.
` THE VIDEOGRAPHER: Anyone on the
` phone, please?
` MR. HOUSTON: Yes, Michael Houston
` of Foley & Lardner representing Renesas.
` MR. SILLIMAN: Michael Silliman of
` Baker, Botts, LLC, on behalf of Toshiba.
` THE VIDEOGRAPHER: And would 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 MR. LAHAV:
`Q. Good morning.
`A. Good morning.
`Q. What did you do to prepare for this
` deposition?
`A. I, over the past two weeks, reread my
` declarations and many of the references.
`
`1
` DR. UWE KORTSHAGEN
`2 Q. Anything else?
`3 A. I had breakfast this morning.
`4 Q. In preparation for your deposition?
`5 A. Yes.
`6 Q. In order to be -- to have nutrition for it,
`7
` is that your statement?
`8 A. Correct.
`9 Q. Okay. Did you meet with any counsel in
`10
` preparation for your deposition?
`11
`A. I did.
`12
`Q. When?
`13
`A. We met on December 2nd, and I think we had a
`14
` number of discussions before that. I don't
`15
` at this point recall the exact dates.
`16
`Q. How long did you meet for on December 2nd?
`17
`A. Excuse me, can you repeat?
`18
`Q. Yes. How long did you meet for on
`19
` December 2nd?
`20
`A. Excuse me. I think we met for six hours
`21
` maybe.
`22
`Q. And with whom did you meet?
`23
`A. I met with the gentlemen who are here at the
`24
` table. So I met with Mr. Fitzpatrick,
`25
` Mr. Tennant, um --
`
`TSG Reporting - Worldwide 877-702-9580
`
`3 (Pages 6 to 9)
`
`

`

`Page 10
`
`Page 11
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
` DR. UWE KORTSHAGEN
`Q. Did you meet with everybody sitting on this
` other side of the table?
`A. At which side of the table?
`Q. The one opposite me.
`A. Correct, yes.
`Q. Okay.
`A. I'm not very good with the last names because
` we --
`Q. I don't know all their names either yet.
`A. Oh, okay.
`Q. Did you spend any time this morning preparing
` for your deposition?
`A. I spent about 20 minutes looking at some
` references, yes.
`Q. Immediately preceding this session; is that
` right?
`A. That is correct, and also maybe 20 minutes at
` home before I actually came here.
`Q. Do you recall how many telephone
` conversations you had to prepare for your
` deposition this morning before the meeting on
` December 2nd?
` MR. FITZPATRICK: Objection to the
` form.
`
`1
` DR. UWE KORTSHAGEN
`2
` THE WITNESS: I do not recall the
`3
` exact number, no.
`4
`BY MR. LAHAV:
`5 Q. Did you have telephone conversations to
`6
` prepare for this deposition with anyone other
`7
` than those sitting across from me at this
`8
` table?
`9
` MR. FITZPATRICK: Objection.
`10
` THE WITNESS: Could you repeat the
`11
` question, please?
`12
` MR. LAHAV: Yes.
`13
`BY MR. LAHAV:
`14 Q. Other than the people sitting across from me
`15
` at this table, did you have telephone
`16
` conversations with any other petitioner's
`17
` counsel in preparation for your deposition
`18
` this morning?
`19 A. I think I should mention that at some of our
`20
` discussions there was a phone conference like
`21
` this and other counsel did call in. I
`22
` don't -- do not recall who actually called
`23
` in. So just for correctness --
`24 Q. Okay.
`25 A. -- I want to state that.
`
`Page 12
`
`Page 13
`
`1
` DR. UWE KORTSHAGEN
`2 Q. Is there any other petitioner's counsel whose
`3
` name you know who participated in a
`4
` preparation session with you for this
`5
` deposition on the phone?
`6
` MR. FITZPATRICK: Objection to
`7
` form.
`8
` THE WITNESS: I think I remember
`9
` that Larissa Park from Wilmer, Hale
`10
` participated at one point. And I believe,
`11
` I'm not a hundred percent certain, I believe
`12
` that the gentleman from Foley & Lardner was
`13
` present at one of the conversations via
`14
` telephone.
`15
`BY MR. LAHAV:
`16 Q. Any other names that you can recall?
`17 A. No.
`18 Q. Please turn to the Kudryavtsev reference. It
`19
` should be in the pile in front of you.
`20 A. Yes.
`21 Q. In Kudryavtsev, in his experimental setup, so
`22
` I'm not right now talking about the math, I'm
`23
` talking about his experiment, there's no
`24
` secondary electron emission; is that correct?
`25 A. I don't think that this is correct.
`
`1
` DR. UWE KORTSHAGEN
`2 Q. Okay. What -- what is secondary electron
`3
` emission?
`4 A. Secondary electron emission is a process by
`5
` which electrons are released, for instance,
`6
` at the cathode of a discharge system when the
`7
` cathode is bombarded by energetic species
`8
` such as ions.
`9 Q. In a sputtering apparatus, when we talk about
`10
` secondary electron emission we are usually
`11
` referring to emission from the target,
`12
` correct?
`13
` MR. FITZPATRICK: Objection to
`14
` form.
`15
` THE WITNESS: I think that the
`16
` target is one of the electrons exposed to the
`17
` plasma from which secondary electrons can be
`18
` released.
`19
`BY MR. LAHAV:
`20
`Q. Isn't it the case that it is the main source
`21
` of secondary electrons in a sputtering
`22
` apparatus?
`23
`A. I do not think that the question can be
`24
` generalized like this. I believe that it
`25
` depends on the specific layout of the
`4 (Pages 10 to 13)
`TSG Reporting - Worldwide 877-702-9580
`
`

`

`Page 14
`
`Page 15
`
`1
` DR. UWE KORTSHAGEN
`2
` sputtering reactor, your questioning.
`3 Q. Okay. Let's take Figure 1 in Wang as an
`4
` example.
`5 A. Yes.
`6 Q. And let's assume that Wang's target is
`7
` copper, okay?
`8 A. Okay.
`9 Q. Is it your opinion that the main source of
`10
` secondary electrons in Wang come from the
`11
` copper target?
`12 A. I think that in Wang's Figure 1 -- excuse
`13
` me -- there will be a significant amount of
`14
` secondary electrons be released from the
`15
` target 14 in Figure 1. I really have to
`16
` speculate to say that this is the main
`17
` source. I think it will be a very important
`18
` source.
`19 Q. What are the other candidates in Figure 1 of
`20
` Wang for secondary electron sources that
`21
` could be greater sources of secondary
`22
` electrons than the target?
`23
` MR. TENNANT: Objection to form.
`24
` THE WITNESS: So, again, I do not
`25
` want to speculate about smaller or larger,
`Page 16
`
`1
` DR. UWE KORTSHAGEN
`2
` but any surface in the plasma reactor that is
`3
` exposed to energetic species, which can
`4
` include ions or photons, is capable of
`5
` contributing to secondary electron emission.
`6
`BY MR. LAHAV:
`7 Q. And the target in Wang is the surface that is
`8
` most exposed to energetic species, correct?
`9
` MR. FITZPATRICK: Objection to the
`10
` form.
`11
` THE WITNESS: The target in Wang
`12
` is exposed to a large flux of energetic
`13
` species, yes.
`14
`BY MR. LAHAV:
`15 Q. And more so than any other surface within
`16
` Wang's reactor, correct?
`17
` MR. FITZPATRICK: Same objection.
`18
` THE WITNESS: I really think
`19
` you're asking me to speculate, because if I
`20
` answer your question with yes, which I do
`21
` not, I think you're trying to tell me that I
`22
` cannot think of conditions where other
`23
` surfaces are equally exposed to high fluxes
`24
` of energetic species. So I do not want to
`25
` speculate.
`
`Page 17
`
`1
` DR. UWE KORTSHAGEN
`2
`BY MR. LAHAV:
`3 Q. So let me add to the hypothetical. Let's
`4
` talk about Figure 1 in Wang with the magnets
`5
` turned on and the magnet is rotating the way
`6
` Wang describes at 1 millitorr of pressure
`7
` with a copper target, and again, operating in
`8
` the normal operating conditions that Wang
`9
` describes in his patent. Do you understand
`10
` that setup?
`11 A. I think I do, yes.
`12 Q. In that case, isn't it true that the target
`13
` is by far the largest source of secondary
`14
` electrons in Wang?
`15
` MR. FITZPATRICK: Object to the
`16
` form.
`17
` THE WITNESS: Are you referring to
`18
` a specific location in the plasma reactor?
`19
` So are you, for instance, implying that close
`20
` to the substrate, the main source of
`21
` secondary electrons found close to the
`22
` substrate would be the target 14?
`23
` MR. LAHAV: That was not my
`24
` question. I meant in the entire reactor.
`25
` MR. FITZPATRICK: Same objection.
`
`1
` DR. UWE KORTSHAGEN
`2
` THE WITNESS: Could you please
`3
` repeat your question?
`4
`BY MR. LAHAV:
`5 Q. I'm going to withdraw the question. Let's
`6
` talk once again about the experiment
`7
` described in Kudryavtsev.
`8
` In Kudryavtsev there is a plasma in a
`9
` tube between two electrodes, correct?
`10 A. That is correct.
`11 Q. And apart from several probes that
`12
` Kudryavtsev inserted into the tube, there is
`13
` nothing else in there, correct?
`14 A. I don't think that this is correct.
`15 Q. Okay. What else is inside the tube?
`16 A. Well, there is, for instance, a gas in there.
`17 Q. What else?
`18 A. I don't know.
`19 Q. As you sit here right now, you're not aware
`20
` of anything else inside Kudryavtsev's tube,
`21
` right?
`22 A. So looking at Figure 2, which describes
`23
` electrical measurements and optical
`24
` measurements that have been performed, it
`25
` suggests that there is electrical access to
`5 (Pages 14 to 17)
`TSG Reporting - Worldwide 877-702-9580
`
`

`

`Page 18
`
`Page 19
`
`1
` DR. UWE KORTSHAGEN
`2
` the electrodes in the tube, it suggests that
`3
` there is optical access to the plasma, so I
`4
` think all of these are elements which may be
`5
` part of Kudryavtsev's plasma reactor.
`6 Q. And by "electrical access" you're referring
`7
` to some sort of wire to bring the voltage to
`8
` the electrode, yes?
`9 A. That is correct. Wires that bring electrodes
`10
` to bring voltage to the electrodes,
`11
` potentially wires that allow for the
`12
` measurements of potentials on electrodes, so
`13
` I think -- can you point me to any specific
`14
` paragraph in Kudryavtsev that were to discuss
`15
` what's within the tube so that I don't have
`16
` to further speculate about what is within the
`17
` tube?
`18
`Q. It's a short article. I don't think that
`19
` Kudryavtsev tells us even as much as you've
`20
` said this morning, so the short answer to
`21
` your question is no. I can point you to the
`22
` Experimental Results section, which begins on
`23
` page 32, if you'd like.
`24
`A. (Reviews document.) Do you have any specific
`25
` question right now?
`
`Page 20
`
`1
` DR. UWE KORTSHAGEN
`2 Q. Yes. By "electrical access" do you mean
`3
` anything other than wires to the electrodes
`4
` or wires that allow measurements?
`5 A. So I believe that maybe I used the term
`6
` electrical access a bit loosely and should
`7
` define what I mean. With electrical access I
`8
` mean means of providing electrical signals,
`9
` such as voltage and current, to a plasma
`10
` reactor, which implies that you need to have
`11
` means to transmit these electrical signals
`12
` from the regular atmospheric environment
`13
` outside the reactor to the controlled gas
`14
` environment inside your reactor.
`15 Q. Is it possible that Kudryavtsev's tube has
`16
` the electrodes just at the end such that the
`17
` wires are actually behind the electrodes and
`18
` sticking out of the tube?
`19 A. I think that is one possibility, yes.
`20 Q. So it is a possibility that the wires are
`21
` actually not inside the tube, right?
`22 A. That is not correct. At least a part of the
`23
` wire needs to be inside the tube to connect
`24
` to the electrode which is inside the tube.
`25 Q. Does Kudryavtsev's optical detector have to
`Page 21
`
`1
` DR. UWE KORTSHAGEN
`2
` be inside the tube?
`3 A. I don't think that the optical detector needs
`4
` to be inside the tube.
`5 Q. We started off this discussion talking about
`6
` secondary electron emission. And my question
`7
` for you is: Apart from the cathode that you
`8
` mentioned, what are the other potential
`9
` sources of secondary electron emission in
`10
` Kudryavtsev's tube?
`11
`A. So, first of all, I want to point out that
`12
` you just said that apart from the cathode
`13
` what are other potential sources of secondary
`14
` electrons, while maybe 15 minutes ago you
`15
` asked the question there are no secondary
`16
` electrons in Kudryavtsev experiment, correct?
`17
` So I think that what you just said
`18
` implies that it is your understanding that
`19
` the cathodes in Kudryavtsev is a source of
`20
` secondary electrons and that Kudryavtsev
`21
` thereby implies secondary electrons.
`22
`Q. So I'm going to ask you a favor. Please do
`23
` not imply anything about my beliefs based on
`24
` my questioning. I have no choice but to live
`25
` in the world that you're setting up in order
`
`1
` DR. UWE KORTSHAGEN
`2
` to ask you questions, so everything I ask you
`3
` is according to your opinion, not mine. Is
`4
` that fair?
`5 A. That is fair. Thank you.
`6 Q. So in your opinion, the cathode is a source
`7
` of secondary electrons in Kudryavtsev,
`8
` correct?
`9 A. That is correct.
`10 Q. And apart from the cathode, in your opinion,
`11
` what are the sources of secondary electrons
`12
` within Kudryavtsev's tube?
`13 A. So in my opinion, there can be other sources
`14
` of secondary electrons in Kudryavtsev's tube,
`15
` and that can include the tube walls. That
`16
` would be one other source.
`17 Q. Please list all of the sources of secondary
`18
` electrons within Kudryavtsev's tube, in your
`19
` opinion.
`20 A. I cannot list all of the sources in
`21
` Kudryavtsev's -- all of the sources for
`22
` secondary electrons in Kudryavtsev's reactor,
`23
` because whether a surface will act as a
`24
` source of secondary electrons or not will
`25
` very much depend on the conditions of the
`6 (Pages 18 to 21)
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`

`

`Page 22
`
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`
`1
` DR. UWE KORTSHAGEN
`2
` plasma that I use. I can happily give you a
`3
` list which may not be complete of potential
`4
` sources.
`5 Q. So Kudryavtsev describes for us the
`6
` conditions within his tube, right?
`7
` MR. FITZPATRICK: Objection.
`8
` THE WITNESS: Kudryavtsev lists a
`9
` number of conditions of properties of the
`10
` plasma within his tube.
`11
`BY MR. LAHAV:
`12 Q. Based on the information that Kudryavtsev
`13
` discloses in his article, please list for me
`14
` the sources of secondary electrons within his
`15
` tube that you know are actual sources of
`16
` secondary electrons, if any.
`17
` MR. FITZPATRICK: Object to the
`18
` form.
`19
` THE WITNESS: So I'll be happy to
`20
` answer that question. Again, I have to
`21
` preface it by saying that this list may not
`22
` be complete, because I may just be forgetting
`23
` one potential source.
`24
` But sources that will contribute with
`25
` some efficiency that I do not know, include
`Page 24
`
`1
` DR. UWE KORTSHAGEN
`2
` THE WITNESS: Yeah, at this point
`3
` I just have to say I do not know.
`4
`BY MR. LAHAV:
`5 Q. And so the list --
`6 A. I believe -- please go ahead.
`7 Q. Yeah. The list for -- of sources that you
`8
` know will contribute at least with some
`9
` efficiency is the cathode, the tube walls and
`10
` the anode, correct?
`11
` MR. FITZPATRICK: Same objection.
`12
` THE WITNESS: Can you repeat the
`13
` question, please?
`14
`BY MR. LAHAV:
`15 Q. The list of sources that you know will
`16
` contribute secondary electrons in
`17
` Kudryavtsev's tube is cathode, tube walls,
`18
` anode, correct?
`19
` MR. FITZPATRICK: Same objection.
`20
` THE WITNESS: The list of sources
`21
` that I know in Kudryavtsev's reactor which
`22
` will contribute secondary electrons with some
`23
` efficiency, which I don't know the
`24
` efficiency, is the cathode, the anode and the
`25
` tube walls.
`
`1
` DR. UWE KORTSHAGEN
`2
` the electron -- the cathodes, the tube walls,
`3
` and to some extent may even include the
`4
` anode.
`5
`BY MR. LAHAV:
`6 Q. As you sit here right now, are you aware of
`7
` any other source within Kudryavtsev's tube
`8
` that will contribute to secondary -- will
`9
` contribute secondary electrons with some
`10
` efficiency?
`11
` MR. FITZPATRICK: Objection to
`12
` form.
`13
` THE WITNESS: Actually, I would
`14
` not be surprised that if even the probes
`15
` which are introduced into Kudryavtsev's
`16
` plasma will contribute secondary electrons
`17
` with some efficiency.
`18
`BY MR. LAHAV:
`19
`Q. So you answered a different question. So I'm
`20
` not interested in what you wouldn't be
`21
` surprised in what somebody told you, but what
`22
` you know contributed to secondary electrons
`23
` in Kudryavtsev's tube as he described it.
`24
` MR. FITZPATRICK: Objection to the
`25
` form.
`
`Page 25
`
`1
` DR. UWE KORTSHAGEN
`2
`BY MR. LAHAV:
`3 Q. And when you talk about efficiency you're
`4
` referring to the fact that it may contribute
`5
` only very little amount of secondary
`6
` electrons or something more than that, right?
`7
` MR. FITZPATRICK: Objection to
`8
` form.
`9
` THE WITNESS: With efficiency I
`10
` mean that this process may occur with a small
`11
` or large probability. Or to rephrase it, it
`12
` may contribute very little or a lot to the
`13
` overall presence of secondary electrons in
`14
` the discharge of Kudryavtsev.
`15
`BY MR. LAHAV:
`16 Q. Please turn to Figure 1 of Kudryavtsev.
`17 A. (Complies.)
`18 Q. Is creation of secondary electrons reflected
`19
` in Figure 1 of Kudryavtsev?
`20 A. I believe that the actual process of creation
`21
` of secondary electrons is not explicitly
`22
` included in Figure 1 of Kudryavtsev.
`23 Q. Is it implicitly included somewhere?
`24
` MR. FITZPATRICK: Objection to
`25
` form.
`
`7 (Pages 22 to 25)
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`
`1
` DR. UWE KORTSHAGEN
`2
` THE WITNESS: Actually, I do
`3
` believe that it is implicitly included.
`4
`BY MR. LAHAV:
`5 Q. Where?
`6 A. Now I'm giving you one example, and that one
`7
` example is in Kudryavtsev's Figure 1, both in
`8
` A and B, the arrow pointing to the right
`9
` labeled gradient of Gamma 2 or Delta
`10
` Gamma 2 -- excuse me, not Delta, it's
`11
` actually -- yeah, I mean it's the gradient
`12
` operator.
`13
`Q. So otherwise referred to as Del? You're
`14
` talking about Del Gamma 2 --
`15
`A. Del Gamma 2.
`16
`Q. -- in Figure 1-A and B?
`17
`A. See, this is where I'm getting confused,
`18
` because Del I think refers to the second
`19
` derivative while the gradient is the first
`20
` derivative.
`21
`Q. So don't take my correction. We'll call it
`22
` the gradient.
`23
`A. Let's call it the gradient Gamma 2. Okay.
`24
` Thank you.
`25
`Q. Okay. So in your opinion, secondary
`
`Page 28
`
`1
` DR. UWE KORTSHAGEN
`2
` electron emission is represented by the
`3
` arrows -- arrows labeled gradient Gamma 2 in
`4
` Figures 1-A and 1-B of Kudryavtsev, correct?
`5 A. That is not correct.
`6 Q. Please correct my statement.
`7 A. What I believe is that the arrow pointing to
`8
` the right labeled gradient Gamma 2 implicitly
`9
` includes a process causing secondary electron
`10
` generation in Kudryavtsev.
`11 Q. Thank you for the clarification.
`12
` Is there any other place in Figure 1 of
`13
` Kudryavtsev that implicitly includes
`14
` secondary electron generation?
`15 A. I believe that there is one other instance.
`16 Q. Where is that?
`17 A. And that is the -- in Figure 1 of
`18
` Kudryavtsev, both in parts A and B, the arrow
`19
` pointing to the right labeled gradient
`20
` Gamma E, and it's at least labeled like this
`21
` in part A of the figure. And I believe that
`22
` the arrow which is in the same position in
`23
` part B of the figure, but which appears to be
`24
` unlabeled, should carry the same label.
`25 Q. Are there any other places in Figure 1 of?
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`
` DR. UWE KORTSHAGEN
` Kudryavtsev that implicitly include secondary
` electron creation, in your opinion?
` MR. TENNANT: Objection to form.
` THE WITNESS: At this moment I
` cannot think of any other place where it
` could implicitly be include it, which does
` not mean that such other place is not
` present, and I would be happy to think about
` it more if you'd like me to do this.
`BY MR. LAHAV:
`Q. I'm going to ask you other questions, but if
` you happen to think of it as we continue
` throughout the day, feel free to inform me if
` you've thought of something further.
`A. I'll be happy to do that. Thank you.
`Q. Gradient Gamma in Kudryavtsev is referred to
` as a diffusion flux, correct?
`A. That is correct.
`Q. What is a diffusion flux?
`A. A diffusion flux is a net flux of species
` caused by a gradient of the density of such
` species, end of sentence.
`Q. And what is the significance of the fact that
` the diffusion fluxes as depicted in Figure 1
`
`1
` DR. UWE KORTSHAGEN
`2
` are horizontal versus vertical?
`3 A. So my understanding of Figure 1 is that the
`4
` vertical direction in Figure 1 describes
`5
` fluxes not in space, but in energy or
`6
` energetic level or excitation level of atoms,
`7
` while the fluxes in horizontal direction
`8
` describe the fluxes of species in space,
`9
` meaning, for instance, from the center of the
`10
` tube to the wall of the tube.
`11
`Q. In Kudryavtsev's mathematical treatment of
`12
` the plasmas that he's investigating, he
`13
` concludes that he's able to neglect Del
`14
` Gamma 2 -- gradient Gamma 2, correct? And I
`15
` point you to page 31, right column, second
`16
` paragraph.
`17
`A. The second paragraph of page 41, right
`18
` column?
`19
`Q. Thirty-one, right column.
`20
`A. Thirty-one, correct. So that we may neglect
`21
` gradient Gamma 2, yes.
`22
` If I may expand on that answer which I
`23
` just gave, I think you previously asked me
`24
` whether secondary electron would implicitly
`25
` be present as represented by Delta Gamma 2,
`8 (Pages 26 to 29)
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`1
` DR. UWE KORTSHAGEN
`2
` and my answer to that was yes, that it was
`3
` implicitly present.
`4
` And I just want to explain that Del
`5
` Gamma -- excuse me, it's gradient Gamma 2
`6
` describes the flux of secondary -- describes
`7
` the flux, and I need to correct myself, the
`8
` flux of excited atoms to the tube wall, and
`9
` that is a process which is known to produce
`10
` secondary electrons, namely, the quenching of
`11
` meta stable atoms at the tube wall by
`12
` transfer of the excitation energy of the meta
`13
` stable atoms to the tube wall has the
`14
` potential to release secondary electrons at
`15
` the tube wall.
`16 Q. And the probability of that is not one, but
`17
` it's just some probability depending on the
`18
` system, correct?
`19
` MR. FITZPATRICK: Object to the
`20
` form.
`21
` THE WITNESS: The probability
`22
` depends on the multitude of factors. It
`23
` depends on the material out of which the tube
`24
` wall is made, the particular condition of the
`25
` tube wall, the particular species that
`
`1
` DR. UWE KORTSHAGEN
`2
` arrive at the tube wall, what kind of meta
`3
` stable atoms we are talking about, yeah.
`4
`BY MR. LAHAV:
`5 Q. So it's only some fraction of meta stable
`6
` atoms that impact a tube wall that would lead
`7
` to ionization, correct?
`8 A. Can you please clarify how you mean that meta
`9
` stable atoms that arrive at the tube wall
`10
` will cause ionization?
`11
`Q. I'm going to withdraw that question and ask
`12
` it differently.
`13
` It's only some fraction of the meta
`14
` stable atoms that impact a tube wall that
`15
` cause secondary electron emission, correct?
`16
` MR. FITZPATRICK: Objection to
`17
` form.
`18
` THE WITNESS: I believe it is
`19
` correct that some fraction of meta stable
`20
` atoms arriving at the tube wall will create
`21
` secondary electrons.
`22
`BY MR. LAHAV:
`23
`Q. Let's look at the Figure 2 of Kudryavtsev,
`24
` please. And Figure 2 reflects measurements
`25
` that Kudryavtsev made, correct?
`
`Page 32
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`Page 33
`
`1
` DR. UWE KORTSHAGEN
`2 A. That is correct.
`3 Q. And curve 2-A shows current, right?
`4 A. Let me just unclip this here just to make
`5
` sure that I have everything in front of me.
`6
` (Reviews document.)
`7
` Yes, 2-A represents the current.
`8 Q. And it is the curve, or at least the rise of
`9
` the curve in 2-A, that Kudryavtsev separates
`10
` into his slow stage and fast stage, correct?
`11
`A. I think it is correct to say that it is the
`12
` relation between the curves 2-A and 2-B which
`13
` motivates Kudryavtsev to separate or to
`14
` distinguish between two different phases
`15
` during the ionization process.
`16
`Q. When Kudryavtsev -- go ahead. Did you want
`17
` to clarify?
`18
`A. Yes, I want to clarify. I should not say
`19
` phases, I should say stages.
`20
`Q. Okay. When Kudryavtsev refers to a slow
`21
` current and a fast current, he's referring to
`22
` the derivative of the curve in A as it rises,
`23
` right?
`24
`A. Could you point me to where Kudryavtsev
`25
` refers to a slow current and a fast current?
`
`1
` DR. UWE KORTSHAGEN
`2 Q. I shall. (Reviews document.) No, I cannot,
`3
` because I don't think he does.
`4
` When -- when Kudryavtsev refers to a slow
`5
` stage, is he talking about th