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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`GLOBALFOUNDRIES, U.S., INC.
`et al.,
`Petitioners,
`vs.
`ZOND, LLC,
`Patent owner.
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` DEPOSITION OF
` UWE KORTSHAGEN, Ph.D.
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`
`Taken July 2, 2015 By Kelly A. Herrick
`Job no. 94926
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`TSG Reporting - Worldwide 877-702-9580
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`Global Foundries et al. v. Zond
`IPR2014-01088 Zond Ex. 2003
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - - - - - - - - - - - - - - - - - - -
`
`GLOBALFOUNDRIES, U.S., INC.
`et al.,
`Petitioners,
`vs.
`ZOND, LLC,
`Patent owner.
`- - - - - - - - - - - - - - - - - - - - - -
`
`- - - - - - - - - - - - - - - - - - - - - - -
`
` DEPOSITION OF
` UWE KORTSHAGEN, Ph.D.
`- - - - - - - - - - - - - - - - - - - - - -
`
`Taken July 2, 2015 By Kelly A. Herrick
`Job no. 94926
`
`TSG Reporting - Worldwide 877-702-9580
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`Global Foundries et al. v. Zond
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`Page 2
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`APPEARANCES:
`ASCENDA LAW GROUP
`333 W. San Carlos Street
`San Jose, California 95110
`By: Tarek Fahmi, Esq.
` For the Patent owner
`
`WHITE & CASE
`701 Thirteenth Street, NW
`Washington, DC 20005
`By: David Tennant, Esq.
` Brett Rismiller (Via telephone)
` For the Petitioner
`
`BAKER BOTTS
`910 Louisiana Street
`Houston, Texas 77002
`By: Robinson Vu, Esq.
` For Toshiba
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` I N D E X
`Examination by Mr. Fahmi, page 4
`
`INDEX OF EXHIBITS
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`NUMBER DESCRIPTION
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`(None marked.)
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` UWE KORTSHAGEN, Ph.D.
` THE DEPOSITION OF UWE KORTSHAGEN, Ph.D. is
` taken on this 2nd day of July, 2015, at The
` Commons Hotel, 615 Washington Avenue SE,
` Minneapolis, Minnesota, commencing at
` 8:04 a.m.
` UWE KORTSHAGEN, Ph.D.,
` A witness in the above-entitled action,
` after having been first duly sworn,
` testifies and says as follows:
` EXAMINATION
` BY MR. FAHMI:
`Q. Would you state your name for the record,
` please.
`A. Yeah, my name is Uwe Richard Kortshagen.
`Q. Dr. Kortshagen, good morning. As you know,
` my name is Tarek Fahmi. I'm here
` representing Zond, and I'll let counsel
` introduce themselves.
` MR. TENNANT: David Tennant with
` White & Case on behalf of GlobalFoundries.
` My colleague, Brett Rissmiller, is with me
` on the phone. And Robinson Vu with Toshiba
` is also on the phone.
` BY MR. FAHMI:
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` UWE KORTSHAGEN, Ph.D.
`Q. Thank you.
` Dr. Kortshagen, I know you've been
` deposed previously, so I'll just go over a
` couple of reminders.
` As you've done in the past, if you
` would please give audible answers to my
` questions this morning, that will help the
` court reporter keep an accurate record of
` the proceeding.
` It's difficult for her to take down
` things like nods of the head or shrugs of
` the shoulders so, if you would, please,
` audible answers. Is that okay?
`A. Yes, that is okay.
`Q. And also, as you've done in the past, if you
` can please wait until I've finished asking a
` question before you give an answer, I'll try
` to do the same and make sure I'm waiting
` until you've finished answering a question
` before I ask another.
` Again, that helps the court
` reporter keep an accurate transcript. Is
` that all right?
`A. Yes, I understand.
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` UWE KORTSHAGEN, Ph.D.
`Q. If at any time this morning I ask a question
` that is unclear, or that you don't
` understand, or that you simply want
` repeated, just let me know, I'll be happy to
` repeat it or rephrase it to try to make it
` more clear, if it was unclear.
` Do you understand?
`A. Yes, I do.
`Q. And by the same token, if you answer a
` question, I'm going to assume that you're
` answering the question that I've asked
` unless you've asked for clarification.
` Is that all right?
`A. That is all right, yes.
`Q. Is there any reason why you couldn't give
` your best testimony here today in this
` proceeding?
`A. No, there's no reason.
`Q. Are you taking any medications that might
` affect your ability to testify truthfully?
`A. No, I do not.
`Q. Any other reason you couldn't give your best
` testimony today?
`A. There's no other reason.
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` UWE KORTSHAGEN, Ph.D.
`Q. Do you have any questions before we begin?
`A. No, I do not.
`Q. I see that you've brought with you to the
` deposition this morning a copy of what looks
` like a Reply Declaration in these
` proceedings; is that correct?
`A. Yes, that's correct.
`Q. May I see that copy, please?
`A. (Handing.)
`Q. Thank you. Thank you. (Handing.)
`A. May I just mention that there are three
` changes in the Declaration. I think you
` noticed the two on page 40 and 43 where the
` reference to Figure 1 in Fahey was,
` unfortunately, through a typo, listed as
` Figure 23, so instead of Figure 23, it
` should say Figure 1. That is on page 40 and
` page 43.
` I'm not sure that you missed --
` that you saw the change on page 23, that is
` in Footnote Number 2, the second to the last
` line on that page where, instead of "high
` pressure vacuum pump," the correct term
` would simply be "a high vacuum pump" on page
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` UWE KORTSHAGEN, Ph.D.
` 23.
` MR. FAHMI: My copy is not
` paginated. Do you know the paragraph?
` MR. TENNANT: (Indicating.)
` MR. FAHMI: Thank you.
` BY MR. FAHMI:
`Q. Thank you.
`A. Thank you.
`Q. When did you make these corrections in your
` Declaration?
`A. I re-read the Declaration yesterday and the
` day before yesterday, and I noticed these
` mistakes yesterday, so I made the specific
` changes, actually, this morning.
`Q. I see. Referring to the correction that was
` made in Footnote Number 2 to correct the
` term "high pressure vacuum pump" to "high
` vacuum pump," is there a distinction between
` those two terms?
`A. Yes. The commonly-used term by those of
` ordinary skill in the art would be "high
` vacuum pump" to suggest that this is a pump
` which produces a very high level of vacuum.
` The term "high pressure vacuum
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` UWE KORTSHAGEN, Ph.D.
` pump" is actually probably never used and
` misleading, so it is more correct to use the
` term "high vacuum pump" for a pump which
` produces a high level of vacuum.
`Q. And the correction to the Fahey drawing
` number was just a typographical error; is
` that right?
`A. Yes, there was a typographical error,
` correct.
`Q. No other corrections required in the
` Declaration?
`A. None that I know of at this point.
`Q. It's my understanding that the single
` Declaration is intended to be used in
` conjunction with the three different IPR
` proceedings involving the '652 patent,
` that's IPR 2014, 00861, 1088 and 1089; is
` that right?
`A. Yes, that is correct.
`Q. If we turn to paragraph 12 of your
` Declaration -- do you prefer to use the copy
` that you brought with you or one that I
` provide you?
`A. However you prefer.
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` UWE KORTSHAGEN, Ph.D.
`Q. I think it's fine if you use the one you
` brought with you.
`A. Thank you.
`Q. And if we turn to paragraph 12, you've
` indicated that it's your understanding that
` the Board has provided a preliminary
` construction for the phrase "super-ionizing
` the initial plasma"; is that right?
` MR. TENNANT: Objection to form.
` THE WITNESS: That is correct, yes.
` BY MR. FAHMI:
`Q. And the Board's initial construction is that
` the phrase "super-ionizing the initial
` plasma" means converting at least 75 percent
` of the neutral atoms in the initial plasma
` into ions; is that right?
` MR. TENNANT: Objection to form.
` THE WITNESS: That is my
` understanding, yes.
` BY MR. FAHMI:
`Q. Do you agree with that construction?
`A. Yes, I do agree with that construction.
`Q. In the next paragraph, paragraph 13, you
` indicate that it's your understanding that
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` UWE KORTSHAGEN, Ph.D.
` the Board has proposed a construction for
` the term "super-ionizing the initial plasma
` proximate to the catheter assembly thereby
` generating a high-density plasma"; is that
` right?
`A. That is correct, yes.
`Q. And that initial construction is converting
` at least 75 percent of the neutral atoms in
` the initial plasma into ions near the
` catheter assembly; is that correct?
` MR. TENNANT: Objection to form.
` THE WITNESS: Yes, that is correct.
` BY MR. FAHMI:
`Q. And do you agree with that construction?
`A. I do agree with that construction, yes.
`Q. In the next paragraph, paragraph 14, you
` provide your understanding of preliminary
` constructions that the Board has reached in
` connection with certain means plus function
` elements in Claim 35 of the '652 patent; is
` that right?
`A. That is correct, yes.
`Q. Do you agree with the Board's constructions
` as set forth in your Declaration?
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` UWE KORTSHAGEN, Ph.D.
`A. Yes, I do agree with that construction.
`Q. And that's true for all of the means plus
` function elements that the Board provided
` preliminary constructions for?
` MR. TENNANT: Objection to form.
` THE WITNESS: Yes, I do agree with
` all the means and function elements.
` BY MR. FAHMI:
`Q. I'd like you to look at the first element in
` the table that's -- is part of paragraph 14
` that is the means for generating an initial
` plasma and excited atoms from a volume of
` feed gas.
` Do you see that?
`A. Yes, I do see that.
`Q. In your opinion, what would a person of
` ordinary skill in the art understand is the
` word "excited function" of that means?
`A. I'm not quite sure that I understand your
` question.
`Q. Okay. The claim term at issue recites means
` for generating an initial plasma and excited
` atoms from a volume of feed gas.
` Do you see that?
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` UWE KORTSHAGEN, Ph.D.
`A. Yes, I do see that.
`Q. So, in that term, there are specified
` certain means, correct?
`A. Yes.
`Q. What is the function of those means as
` understood by a person of ordinary skill in
` the art?
` MR. TENNANT: Objection to form.
` THE WITNESS: Well, the function
` is, according to my understanding,
` generating initial plasma and excited atoms
` from a volume of feed gas.
` BY MR. FAHMI:
`Q. Would the person of ordinary skill in the
` art understand that it is the same means
` that generates both the initial plasma and
` excited atoms from the volume of feed gas?
` MR. TENNANT: Objection to form.
` THE WITNESS: I believe that a
` person of ordinary skill would understand
` that commonly one would use one mean to
` generate an initial plasma and excited atoms
` from a volume of feed gas, but that there
` would also be -- that there could also be
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` UWE KORTSHAGEN, Ph.D.
` more than one mean of doing that.
` BY MR. FAHMI:
`Q. So, I'm thinking specifically now of the
` context of the '652 patent. You're familiar
` with the '652 patent, yes?
`A. It is a very lengthy document. I am
` relatively familiar with it, yes.
`Q. When is the last time you had a chance to
` review it?
`A. I reviewed it over the weekend.
`Q. Dr. Kortshagen, I've handed you a copy of
` what's been previously marked as
` Exhibit 1001 in at least the '861
` proceeding.
` Do you recognize this as the '652
` patent?
`A. I do, yes.
`Q. This is the patent that's the subject of
` your Declaration, correct?
`A. That is correct, yes.
`Q. You should feel free to refer to it during
` our discussion. So, I'm thinking
` specifically of the context of the '652
` patent and the means for generating an
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` UWE KORTSHAGEN, Ph.D.
` initial plasma and excited atoms from a
` volume of feed gas as recited in Claim 35 of
` the patent.
` Do you understand that?
`A. Please -- I'm sorry. Please repeat your
` question.
`Q. Sure. I'm just trying to set the context --
`A. Yes.
`Q. -- for the next question.
` The context will be, concerning the
` '652 patent, and more specifically the means
` for generating an initial plasma and excited
` atoms from a volume of feed gas as recited
` in Claim 35 of the '652 patent.
` Do you understand that?
`A. I do understand that, yeah.
`Q. So, in that context, would the person of
` ordinary skill in the art understand that it
` is the same means that is generating the
` initial plasma and the excited atoms from a
` volume of feed gas?
` MR. TENNANT: Objection to form.
` THE WITNESS: I believe a person of
` ordinary skill would understand that this is
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` UWE KORTSHAGEN, Ph.D.
` the most common way of achieving that,
` having one means of generating an initial
` plasma and excited atoms from a volume of
` feed gas.
` BY MR. FAHMI:
`Q. And would you also understand that the
` person of ordinary skill in the art would
` understand that the term means for
` generating an initial plasma and excited
` atoms from a volume of feed gas means that
` both the initial plasma and excited atoms
` are generated from the same volume of feed
` gas?
` MR. TENNANT: Objection to form and
` relevance.
` THE WITNESS: I think a person of
` ordinary skill would understand that the
` generation of an initial plasma and excited
` atoms go hand-in-hand and are very difficult
` to separate from each other, if at all
` possible.
` So, from that point of view, I
` believe that a person of ordinary skill
` would understand that generating an initial
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` UWE KORTSHAGEN, Ph.D.
` plasma and excited atoms from a volume of
` feed gas occurs within the same volume.
` BY MR. FAHMI:
`Q. The same volume of feed gas; is that right?
` MR. TENNANT: Objection to form;
` relevance.
` THE WITNESS: The same volume of
` feed gas, yes.
` BY MR. FAHMI:
`Q. Dr. Kortshagen, I've now handed you what's
` been previously marked as Exhibit 1003 in
` the '861 proceeding.
` Do you recognize this as the
` Mozgrin reference?
`A. I do, yes.
`Q. And the Mozgrin reference is one of the
` items that you considered in connection with
` the reply Declaration that you submitted; is
` that right?
`A. That is correct, yes.
`Q. When is the last time you've had an
` opportunity to review it?
`A. I reviewed at least parts of it yesterday
` evening.
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` UWE KORTSHAGEN, Ph.D.
`Q. If you wouldn't mind turning to Figure 3 of
` Mozgrin, it's on page 402 of the reference.
`A. Yes, I'm looking at this figure now.
`Q. Can you tell me what is depicted in
` Figure 3?
`A. Yes. Figure 3, according to the figure
` caption of that figure, shows oscillograms
` of the current, which is depicted in
` subfigure A, and the voltage, which is
` depicted in subfigure B of that figure, and
` these current and voltage wave forms refer
` to a quasi-stationary discharge.
` The figure caption also talks about
` the time resolution on the oscilloscope that
` was used, the current resolution, and the
` voltage resolution.
`Q. What is in an oscillogram?
`A. Oh, an oscillogram is a visual
` representation of electrical signals that is
` produced by an instrument which is known as
` an oscilloscope.
`Q. So, if I understand correctly, the wave
` forms that are represented in Figure 3 are
` illustrations of what one would see on an
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` UWE KORTSHAGEN, Ph.D.
` oscilloscope display if you performed the
` experiments that are described by Mozgrin
` under those conditions that the experiments
` were performed under; is that right?
` MR. TENNANT: Objection to form.
` THE WITNESS: Yes, that is correct,
` yes.
` BY MR. FAHMI:
`Q. The figures include, along the horizontal
` axis, certain numbers, 1, 2a, 2b, and 3.
` Do you see that?
`A. I do.
`Q. Do you have an understanding of what those
` numbers are representing?
`A. I do believe that I have a general
` understanding of what these numbers
` represent, yes.
`Q. What is that understanding?
`A. If you would give me one moment to refresh
` my memory because, in our most recent
` discussion focusing on these supplement
` Declaration, I have not paid a lot of
` attention to Figure 3, so I would like to
` refresh my memory for a moment, please.
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` UWE KORTSHAGEN, Ph.D.
`Q. Sure. Take your time.
`A. So, it is my understanding that the Numbers
` 1, 2a, 2b, and 3 in Figure 3 represent
` different phases of the evolution of the
` magnetron discharge in Mozgrin during the
` application of a high-voltage pulse.
` Figure 3 is actually explained in
` good detail in the right-hand column of page
` 402, the second paragraph in that column.
` According to that explanation, the
` number 1 corresponds to the stage that we
` have referred to commonly as the
` pre-ionization stage where a stationary
` discharge voltage is applied.
` Part 2a then displays the
` application of the high-voltage pulse, which
` Mozgrin describes as a square-voltage pulse.
` During Part 2b, the plasma density
` increases rapidly in response to the
` application of the high-voltage pulse during
` Part 2a, and at the end of Part 2b, the
` plasma density and the discharge current
` that is closely linked with the plasma
` density reach a quasi-stationary value.
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` UWE KORTSHAGEN, Ph.D.
` During the increase of the plasma
` density, the discharge voltage in Part 2b
` actually decreases because the resistivity
` of the plasma decreases, and when, at the
` end of Part 2b, a quasi-stationary state is
` reached, then the discharge enters into Part
` 3, which is the quasi-stationary discharge.
`Q. Also on page 402, there's shown Figure 4.
` Do you see that?
`A. I do see that, yes.
`Q. Figure 4 also has reference to numbers 1, 2,
` 3, and also has a reference Number 4.
` Do you see that?
`A. I do see that, yes.
`Q. Is there any correlation between those
` numbers, 1, 2, and 3 in Figure 4, and the 1,
` 2a, 2b, and 3 in Figure 3?
` MR. TENNANT: Objection: Form.
` THE WITNESS: Well, please let me
` take another moment to refresh my memory
` with respect to Figure 4.
` Mr. Fahmi, first let me preface my
` answer by saying that I believe this
` question has been addressed in great detail
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` UWE KORTSHAGEN, Ph.D.
` in my original Declarations, which now I do
` not have in front of me, and I believe
` whatever was expressed in these original
` Declarations to be correct.
` But in order to answer your
` question, which I'm now doing from memory, I
` believe that it is fair to say that there is
` some correlation between the numbers used in
` Figure 3 and 4, but not necessarily a 1-to-1
` correlation.
` And I'll be happy to explain this
` in more detail if you would like, but I'm
` not sure that you like that to be the case.
` BY MR. FAHMI:
`Q. So, with reference to Figure 3, you
` indicated that Number 1 represented a
` pre-ionization stage; is that right?
`A. That is correct, yes.
`Q. Does the Number 1 in Figure 4 also represent
` a pre-ionization stage?
` MR. TENNANT: Objection to form and
` relevance.
` THE WITNESS: Yes, it would be my
` understanding that this would correspond to
`
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` UWE KORTSHAGEN, Ph.D.
` current and voltage values that are typical
` for the pre-ionization stage.
` BY MR. FAHMI:
`Q. In referring to page 401 in Mozgrin, I
` believe it's the left-hand column, the
` fourth paragraph in that column, Mozgrin
` reports a pre-ionized plasma density.
` Do you see that?
`A. Yes, I do see that.
`Q. And it's correct that he reports a necessary
` pre-ionized plasma density to be in the
` range of 10 to the 7 to 10 to the 9 per
` cubic centimeters for argon; is that right?
`A. Yes, the sentence specifically states: The
` necessary pre-ionized plasma density n(i)
` turned out to be 10 to the power 7 to 10 to
` the power 9 per cubic centimeter for argon.
`Q. In the sentence that you just read, the
` parameter n(i) refers to the ion density; is
` that right?
`A. The parameter n(i) in this sentence is
` called the plasma density by Mozgrin, and
` this choice of words reflects the knowledge
` of those of ordinary skill in the art that,
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` UWE KORTSHAGEN, Ph.D.
` in a plasma, the ion density typically
` labeled n(i) and the electron density
` typically labeled n(e) are, essentially,
` equal and thus often synonymously used with
` the same term, plasma density.
`Q. So, the plasma density that Mozgrin is
` reporting in this passage is for the
` pre-ionized plasma, correct?
`A. That's correct, yes.
` MR. TENNANT: Objection. Objection
` to form.
` BY MR. FAHMI:
`Q. And the pre-ionized plasma corresponds to
` Part 1 in Figure 3, correct?
` MR. TENNANT: Objection to form and
` relevance.
` THE WITNESS: Yes, that is correct.
` BY MR. FAHMI:
`Q. Referring, again, to Figure 3, the region
` that is covered by 2a and 2b, would that be
` the region that represents a high-density
` plasma stage?
` MR. TENNANT: Objection to form;
` relevance.
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` UWE KORTSHAGEN, Ph.D.
` THE WITNESS: Could you repeat your
` question, please.
` BY MR. FAHMI:
`Q. Sure. In Figure 3 of Mozgrin, the region
` that includes Parts 2a and 2b, is that a
` region that represents a high-density plasma
` stage?
` MR. TENNANT: Same objections.
` THE WITNESS: I do not believe that
` it can be expressed like that. I believe
` that the Parts 2a and 2b of Figure 3
` represent a transitional stage during which
` both voltage and current change and reflect
` the evolution of the plasma from a
` pre-ionized plasma to a high-density plasma.
` BY MR. FAHMI:
`Q. What about the Region 2 in Figure 4, is that
` a region that represents a high-density
` plasma?
` MR. TENNANT: Objection to
` relevance.
` THE WITNESS: I'm sorry that I've
` taken a minute here. Could you be so kind
` to repeat your question.
`
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` UWE KORTSHAGEN, Ph.D.
` BY MR. FAHMI:
`Q. Sure. I'm referring to Region 2 in Figure 4
` of Mozgrin, and the question was whether, in
` your opinion, that is a region that
` represents a high-density plasma.
` MR. TENNANT: Objection to form and
` relevance.
` THE WITNESS: I believe that if we
` apply a definition of high-density plasma as
` we have done in the past, that a
` high-density plasma is a plasma of
` relatively high-peak plasma density, and a
` low-density plasma, one of relatively
` low-peak plasma density, then it would be
` correct to refer to Region 2 of Figure 4 as
` a high-density plasma and, specifically
` Mozgrin, on page 2 -- 402, right column, the
` last paragraph on this page refers to this
` regime as the high-current magnetron
` discharge.
` BY MR. FAHMI:
`Q. Let's look briefly at the '652 patent, and
` if I can invite your attention to column 8
` near the bottom of the column, it's actually
`
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` UWE KORTSHAGEN, Ph.D.
` the last sentence of the paragraph beginning
` at about line 59.
` The '652 patent indicates that
` weakly ionized argon plasma is a plasma that
` has a peak plasma density that is in the
` range of 10 to the 7 to 10 to the 12 per
` cubic centimeters.
` Do you see that?
`A. I do see that, yes.
`Q. And elsewhere, I believe the '652 patent
` indicates that a strongly ionized plasma is
` one that has an ion density greater than
` about 10 to the 12 per cubic centimeters,
` and for reference, that's in column 16 at
` about lines 39 through 41.
` Do you see them?
`A. Yes, column 16, line 40, says, the
` high-density plasma has an ion density that
` is greater than about 10 to 12 per cube
` centimeter, yes.
`Q. And then, if we go back to Mozgrin, Mozgrin
` page 409, the last page, and we look at the
` left-hand column, the paragraph that begins,
` "In conclusion," and Mozgrin appears to
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` UWE KORTSHAGEN, Ph.D.
` indicate that, in regime 2, the plasma
` density exceeded 2 times 10 to the 13 per
` cubic centimeter.
` Do you see that?
`A. Yes, I do see that.
`Q. So, if we apply the definitions of weakly
` ionized plasma and strongly ionized plasma
` from the '652 patent, is it correct that, in
` Mozgrin's regime 2, it is a region of
` high-density plasma?
` MR. TENNANT: Objection to form and
` relevance.
` THE WITNESS: I believe it is
` correct that, if we apply the definition of
` the '652 patent, regime 2 represents a
` regime of high-density plasma.
` BY MR. FAHMI:
`Q. A little bit further down on page 409 of
` Mozgrin, there's reference to the
` high-current diffuse discharge of regime 3
` and the plasma density of 1.5 times 10 to
` the 15 per cube centimeter.
` Do you see that?
`A. I do see that, yes.
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` UWE KORTSHAGEN, Ph.D.
`Q. So, again, applying the definitions of the
` '652 patent, is it correct that Mozgrin's
` regime 3 represents a regime of high-density
` plasma?
` MR. TENNANT: Objection to form and
` relevance.
` THE WITNESS: That's correct, yes.
` MR. FAHMI: We've been going for
` about an hour. Would you care for a break?
` THE WITNESS: If you like, we can
` get going.
` MR. FAHMI: You prefer to keep
` going? It's entirely up to you, sir.
` THE WITNESS: Why don't we take a
` five-minute break.
` MR. FAHMI: Sure.
` THE WITNESS: Thank you.
` (A recess was taken.)
` BY MR. FAHMI:
`Q. Let's turn to paragraph 29 of your
` Declaration, please.
`A. Yes.
`Q. In paragraph 29, there's a table set forth
` that compares certain parameters discussed
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` UWE KORTSHAGEN, Ph.D.
` in the '652 patent with similar parameters
` discussed in Mozgrin; is that right?
`A. That is correct, yes.
`Q. And I'm looking at the column for Mozgrin in
` the row concerning generating the
` high-density plasma.
` It indicates that the high-power
` pulse was 100 kilowatts.
` Do you see that?
`A. I do see that, yes.
`Q. And you cite Mozgrin at page 404, the second
` paragraph of the right-hand column, yes?
`A. Yes, that is correct.
`Q. How did you determine that the high-power
` pulse was 100 kilowatts from that citation
` to Mozgrin?
`A. Yeah, give me just a second.
`Q. Sure.
`A. So, specifically how the power of 100
` kilowatts is determined is explained in
` paragraph 27 of my Declaration.
` In order to determine the power, it
` is necessary to know both the voltage and
` the current in that regime and, as explained
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` UWE KORTSHAGEN, Ph.D.
` in paragraph 27, Mozgrin explains that a
` diffuse regime of the high current discharge
` is associated with a discharge voltage
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