UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` SHARP CORPORATION, :
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` SHARP ELECTRONICS :
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` CORPORATION, and SHARP :
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` ELECTRONICS : CASE IPR2015-00021
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` MANUFACTURING COMPANY :
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` OF AMERICA, INC., : Patent No.
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` Petitioners, : 7,202,843 B2
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` v. :
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` SURPASS TECH :
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` INNOVATION, LLC, :
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` Patent Owner. :
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`- - - - - - - - - - - - - -x
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` DEPOSITION OF MICHAEL J. MARENTIC
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` New York, New York
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` Tuesday, October 6, 2015
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` 9:30 a.m.
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`Job No.: 94092
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`Pages: 1 - 167
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`Reported By: Dana N. Srebrenick, CRR, CLR
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`Ex. 2007
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`Page 1 of 476
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`
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` SHARP CORPORATION, :
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` SHARP ELECTRONICS :
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` CORPORATION, and SHARP :
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` ELECTRONICS : CASE IPR2015-00021
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` MANUFACTURING COMPANY :
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` OF AMERICA, INC., : Patent No.
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` Petitioners, : 7,202,843 B2
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` v. :
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` SURPASS TECH :
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` INNOVATION, LLC, :
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` Patent Owner. :
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`- - - - - - - - - - - - - -x
`
` DEPOSITION OF MICHAEL J. MARENTIC
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` New York, New York
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` Tuesday, October 6, 2015
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` 9:30 a.m.
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`Job No.: 94092
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`Pages: 1 - 167
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`Reported By: Dana N. Srebrenick, CRR, CLR
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` Deposition of MICHAEL J. MARENTIC, held at the
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`offices of:
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`2
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` AMSTER ROTHSTEIN & EBENSTEIN LLP
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` 90 Park Avenue
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` New York, New York 10016
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` 212.336.8063
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` Pursuant to notice, before Dana N. Srebrenick, CRR,
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`CLR, Notary Public in and for the State of New York.
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`3
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` A P P E A R A N C E S
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` ON BEHALF OF PETITIONER:
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` MARK BERKOWITZ, ESQUIRE
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` AMSTER ROTHSTEIN & EBENSTEIN LLP
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` 90 Park Avenue
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` New York, New York 10016
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` 212.336.8063
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` mberkowitz@arelaw.com
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` ON BEHALF OF PATENT OWNER:
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` WAYNE HELGE, ESQUIRE
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` JAMES T. WILSON
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` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
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` 8300 Greensboro Drive, Suite 500
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` McLean, Virginia 22102
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` 571.765.7714
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` whelge@dbjg.com
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` jwilson@dbjg.com
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` - - -
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` I N D E X
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` Testimony of:
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` MICHAEL J. MARENTIC
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` BY MR. HELGE............................. 6
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` BY MR. BERKOWITZ......................... 160
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` BY MR. HELGE............................. 163
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` E X H I B I T S
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` No. Description Page
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` Exhibit A Declaration of Michael J.
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` Marentic in Support of
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` Petition for Inter Partes
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` Review, U.S. Patent
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` No. 7,420,550.............. 24
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` Exhibit B Petition for Inter Partes
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` Review of U.S. Patent
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` 7,202,843 ................. 35
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` E X H I B I T S (CONT.)
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` No. Description Page
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` Exhibit C Copy of United States
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` Patent No. 4,464,657....... 51
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` P R O C E E D I N G S
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` MICHAEL J. MARENTIC, residing at 22075 White
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`Peaks Drive, Bend, Oregon 97702 having first been duly
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`sworn by the Notary Public of the State of New York, was
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`6
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`examined and testified as follows:
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` - - -
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` EXAMINATION BY MR. HELGE:
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` - - -
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` Q Good morning, Mr. Marentic.
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` A Good morning.
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` Q We are here for the deposition in the case of
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`Sharp Corporation, Sharp Electronics Corporation and
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`Sharp Electronics Manufacturing Company of America, Inc.
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`v. Surpass Tech Innovation, LLC, Case No. IPR2015-00021,
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`relating to Patent 7,202,843, and we're here to take
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`your deposition.
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` Is that your understanding as well?
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` A It is.
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` Q Mr. Marentic, you've been deposed before,
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`correct?
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` A That's correct.
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` Q Do you know how many times?
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`Deposition of Michael J. Marentic
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` A Four to six times.
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` Q Okay.
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` A And one of them was a multiple-day deposition.
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` Q Okay. And at the beginning of each of those
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`depositions, was there some explanation to you of the
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`rules for the deposition?
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` A Yes, there was.
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` Q Okay. I will go through the rules for us
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`today, just for clarification. If you have any
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`questions, please let me know. And actually, throughout
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`the day, if you don't understand any question I ask you,
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`please let me know.
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` Do you agree to do that?
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` A I do.
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` Q Thank you.
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` One of the typical rules is we won't talk over
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`each other.
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` Do you understand?
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` A Yes.
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` Q Thank you.
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` Can I ask you, are you taking any medications
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`today that would affect your testimony or would affect
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`or even impair your ability to give true and accurate
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`8
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`testimony?
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` A No.
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` Q Is there any other reason why you might not be
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`able to give true and accurate testimony today?
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` A No.
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` Q Mr. Marentic, you were with us in San Diego
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`and you heard Mr. Lo Cicero read a paragraph from the
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`Office Patent Trial Practice Guide. And I'm going to
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`read that same paragraph here for us today.
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` That paragraph states, "Once the
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`cross-examination of a witness has commenced, and until
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`cross-examination of the witness has concluded, counsel
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`offering the witness on direct examination shall not:
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`(a) Consult or confer with the witness regarding the
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`substance of the witness' testimony already given, or
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`anticipated to be given, except for the purpose of
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`conferring on whether to assert a privilege against
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`testifying or on how to comply with a Board order; or
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`(b) suggest to the witness the manner in which any
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`questions should be answered."
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` Do you understand the paragraph as I've just
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`Conducted on October 6, 2015
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`9
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`read it?
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` A I understand the content.
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` Q Okay. And do you understand that this
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`paragraph will govern our behavior today until the
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`conclusion of the deposition at the end of the day?
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` A Yes.
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` Q And so that prohibition against conferring
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`with your attorneys, it will continue even when I've
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`concluded with my examination and while your attorneys
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`are preparing their rebuttal testimony -- or their
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`rebuttal examination.
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` Do you understand that?
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` A Can you explain that?
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` Q Absolutely. Absolutely.
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` So I'll be asking questions today.
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` A Yes.
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` Q And at some point I'll say, "I have no further
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`questions." And then your attorney will have an
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`opportunity to ask you some questions.
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` This prohibition against conferring with your
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`attorney continues during that break period, and so
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`they're prohibited from conferring with you and telling
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`you what questions they're about to ask and guiding you
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`on that.
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` Does that make sense?
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` A That makes sense. Thank you.
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` Q So, Mr. Marentic, just for clarification, am I
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`pronouncing your name correctly, Marentic?
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` A Correctly, yeah, Marentic.
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` Q Thank you.
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` Okay, Mr. Marentic, can I ask you what you did
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`to prepare for today's deposition?
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` A I read my declaration. I read the Ham patent.
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`I read the '843 Shen patent. I may have reviewed some
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`of the other documents that are cited in my declaration.
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`And met with Mr. Berkowitz a few times.
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` Q Did you talk to anybody else in preparation
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`for this deposition?
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` A Briefly, Tony Lo --
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` MR. BERKOWITZ: Lo Cicero.
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` A Lo Cicero, yes, came in and briefly --
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`BY MR. HELGE:
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` Q I'm going to stop you right there. I'm
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`definitely not asking for the contents of those
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`discussions. I just want to know the identities of the
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`persons.
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` A Brian Cormack.
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` MR. BERKOWITZ: Comack.
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` A Comack.
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` So the three --
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`BY MR. HELGE:
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` Q The attorneys?
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` A The three attorneys from Amster, Rothstein &
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`Ebenstein.
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` Q Did you speak with any colleagues or people
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`that you know from your private practice in your
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`experience as listed on your CV in preparation for this
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`deposition?
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` A No.
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` Q Did you speak with any of those people prior
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`to preparing your reply declaration?
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` MR. BERKOWITZ: Objection to form.
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` MR. HELGE: That's a good point. Let me
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`clarify that question.
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`BY MR. HELGE:
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` Q While you were in the process of preparing
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`your reply declaration, did you speak to any of the
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`people that you knew from your time in private practice
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`or in any of your employment with -- that's shown on
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`12
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`your CV?
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` A No.
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` Q Do you recall the last time you reviewed the
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`petition that Sharp filed in this case?
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` A Not precisely.
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` Q You reviewed it prior to preparing your reply
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`declaration, right?
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` A Yes.
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` Q And when I say "reply declaration," just for
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`clarification, I'm referring to what's been marked in
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`this case as Sharp Exhibit 1010. It's entitled
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`"Rebuttal Declaration of Michael J. Marentic in Support
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`of Petitioner's Reply to Patent Owner's Response. "
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` A Yes.
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` Q Was that your understanding when I asked you
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`that question as well?
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` A Yes.
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` Q While you were reviewing that petition, did
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`you see any statements or characterizations that you
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`disagreed with?
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` A No.
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` Q So you agreed with everything in the petition?
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` A Yes. It was logical, straightforward,
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`understandable.
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` Q So I understand that you weren't involved with
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`this case at that stage, while the petition was filed?
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` MR. BERKOWITZ: Objection to form.
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` MR. HELGE: I'll re-ask the question.
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`BY MR. HELGE:
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` Q So I understand that you did not file a
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`declaration in support of that petition; is that right?
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` A That is correct.
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` Q Looking back at the petition, is there
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`anything that you would have done differently had you
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`been involved with the case at that stage?
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` MR. BERKOWITZ: Objection. Foundation.
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`Relevance.
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` A I believe the petition was clear and
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`understandable.
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` Q And the petition -- or, excuse me.
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` The theories of the case as expressed in your
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`Conducted on October 6, 2015
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`reply declaration, those theories are all consistent
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`14
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`with the petition, right?
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` A I believe so, yes.
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` Q So the petition is technically sound in your
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`opinion?
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` MR. BERKOWITZ: Object --
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` A Yes.
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` MR. BERKOWITZ: Just objection to foundation.
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`BY MR. HELGE:
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` Q Mr. Marentic, you've read the petition, right?
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` A I have read the petition.
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` Q And you have experience in LCD technology,
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`correct?
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` A I do.
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` Q And you understand the '843 patent, correct?
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` A I do.
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` Q And you understand the Ham reference, correct?
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` A I do.
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` Q Was there anything in the petition that you
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`didn't understand?
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` MR. BERKOWITZ: Objection to foundation and
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`relevance.
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`15
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` A When I read the petition, it was given to me
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`after the Patent Trial and Review Board had issued their
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`decision. So the patent -- the section that I
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`concentrated on was principally that of Ham, and breezed
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`through the other sections that related to other
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`patents. I principally read Ham -- the Ham section at
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`the end of the petition.
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`BY MR. HELGE:
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` Q And you didn't see anything in that section
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`that you disagreed with?
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` MR. BERKOWITZ: Objection. Foundation.
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` A Everything there was clear and made sense to
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`me.
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`BY MR. HELGE:
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` Q And your theories are consistent with that
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`petition?
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` MR. BERKOWITZ: Again, same objection.
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`Objection, foundation.
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` A My analysis is consistent with that.
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`BY MR. HELGE:
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` Q So you haven't deviated from those theories of
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`invalidity as expressed in the petition; is that right?
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` MR. BERKOWITZ: Objection to form.
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`Foundation.
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` A I agreed with the Ham section of the petition.
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`I find no errors and have no disagreements with it.
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`BY MR. HELGE:
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` Q And your theories of invalidity as expressed
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`in your reply declaration are consistent with the
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`petition, correct?
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` MR. BERKOWITZ: Objection to form.
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`Foundation.
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` A My declaration is a rebuttal to the patent
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`owner's response and to Mr. Bohannon's written
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`declaration. And those sections where the patent owner
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`or Mr. Bohannon disagree with the petition, I find
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`several of those in error. And that is reported in --
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`in my rebuttal declaration.
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`BY MR. HELGE:
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` Q Mr. Marentic, I'm not trying to trick you. I
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`really just want to understand whether you think that
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`the theories of invalidity expressed in your rebuttal
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`declaration are consistent with the theories of
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`invalidity as expressed in the petition.
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` Does that make sense?
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` MR. BERKOWITZ: Objection to form.
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` A My technical analysis in -- in my rebuttal is
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`consistent with the technical section of Ham in the
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`17
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`petition.
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`BY MR. HELGE:
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` Q So you haven't presented any new invalidity
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`theories in your declaration; is that right?
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` MR. BERKOWITZ: Objection to form.
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`Foundation.
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` A My declaration is a rebuttal to the patent
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`owner's response and Mr. Bohannon's declaration.
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`BY MR. HELGE:
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` Q Let's talk about your experience a little bit.
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`You've been deposed, you said, about four to six times;
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`is that right?
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` A Correct.
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` Q Were those all patent cases?
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` A They were.
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` Q And were those all cases in which you were
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`presented as an expert in either validity areas or
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`infringement areas?
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`Deposition of Michael J. Marentic
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` MR. BERKOWITZ: Objection to form.
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` A The cases that I was deposed for were for
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`patent-related issues in invalidity or infringement.
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`BY MR. HELGE:
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` Q And you were presented as an expert on behalf
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`of your party; is that right?
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` A That is correct.
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` Q In those cases, did you have to construe
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`claims as part of your role as an expert?
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` MR. BERKOWITZ: Objection to form.
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` A In a couple of instances, the claims were
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`construed at a Markman hearing and they were done
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`outside my area of -- well, outside my participation.
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` Q And so in those cases you were asked to
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`provide an opinion using those constructions, right?
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` A Correct.
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` Q Okay. In any of those cases, were you asked
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`to provide an opinion on the proper construction of
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`claim terms?
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` MR. BERKOWITZ: Objection to form.
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` A I don't recall any.
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`BY MR. HELGE:
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` Q So would you say that this case is the first
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`instance in which you've been asked to provide an
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`opinion on the proper construction of claim terms?
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` MR. BERKOWITZ: Objection to form.
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`Foundation.
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` A I don't believe I've been asked to provide
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`claim construction input.
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`BY MR. HELGE:
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` Q So let me ask you this: Do you have no
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`opinion on the proper construction of terms at issue in
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`the '843 patent?
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` MR. BERKOWITZ: Objection to form.
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` A I took note that the original petition did not
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`ask for any terms to be construed. I note -- noted that
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`the preliminary patent owner's response did not ask for
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`any claims to be construed. And I noticed that the
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`Patent Trial and Review Board chose not to construe any
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`terms.
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`BY MR. HELGE:
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` Q So you have no opinion on the construction of
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`any terms; is that right?
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` MR. BERKOWITZ: Objection to form.
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` A The terms have not been construed by those
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`prior documents or review board. So there is no
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`claim -- specific claim construction, as I've seen in
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`the past, where this term means this thing and I need to
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`plug in that longer phrase for a word or two. This case
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`has none of that.
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`BY MR. HELGE:
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` Q You understand that to establish invalidity of
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`a patent claim, you have to consider each word in that
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`claim, correct?
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` MR. BERKOWITZ: Objection to form.
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` A Could you repeat the question?
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` (Whereupon, the question is read back by the
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`reporter.)
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` A Yes.
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`BY MR. HELGE:
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` Q And to consider each word in that claim, you
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`need to understand what each of those words mean in the
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`claim, correct?
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` MR. BERKOWITZ: Objection to form.
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` A That would be by a person -- as read by a
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`person of ordinary skill in the art.
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`BY MR. HELGE:
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` Q So to consider each word in the claim, we
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`would need to have the meaning of each word in that
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`claim known as it would be understood by a person of
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`ordinary skill in the art, correct?
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` MR. BERKOWITZ: Objection to form.
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` A When the specification and the claims are read
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`together by a person of ordinary skill in the art, every
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`word in the claim should be considered.
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`BY MR. HELGE:
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` Q When you just said "when the specification and
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`the claims are read together by a person of ordinary
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`skill in the art," what did you mean by that?
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` A The claims aren't an isolated item. The
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`specification isn't an isolated item. The two together
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`form the patent with the figures and the claims refer to
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`words or concepts described in the words section of the
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`patent.
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` Q And by words section of the patent, are you
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`talking about the specification?
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` A The specification, the abstract, the prior
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`art, the summary, and then the description.
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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` Q Is there any part of the specification that's
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`22
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`more important than another part?
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` MR. BERKOWITZ: Objection to form.
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`Foundation.
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`BY MR. HELGE:
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` Q Mr. Marentic, don't answer that question. I'm
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`going to ask that again.
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` Is there any part of the specification that's
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`more important than another part when you are construing
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`claim terms?
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` MR. BERKOWITZ: Objection to form.
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` A I don't know. That sounds like an excellent
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`legal question. That situation didn't come up here so I
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`would need to have some expert legal input to answer
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`that question.
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`BY MR. HELGE:
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` Q In your time as an expert, have you developed
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`a standard practice for construing claim terms?
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` MR. BERKOWITZ: Objection to the form.
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`Foundation.
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` A As I mentioned earlier, I haven't construed
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`terms -- I haven't construed terms. The court has
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`construed terms.
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`BY MR. HELGE:
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` Q Have you construed terms in any other
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`proceedings before the Patent Trial and Appeal Board?
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` A No.
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` MR. BERKOWITZ: Objection to form.
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`BY MR. HELGE:
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` Q Did you submit a declaration in support of a
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`petition for inter partes review of Surpass's '550
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`patent?
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` MR. BERKOWITZ: Objection to relevance.
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` A I did.
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`BY MR. HELGE:
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` Q And in preparing that declaration, did you
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`provide any opinions on claim construction?
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` MR. BERKOWITZ: Objection to form.
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` A I have not read that declaration since it was
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`submitted and don't have a recollection of whether terms
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`were construed or not.
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` MR. HELGE: I'm going to ask that this be
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`marked with an exhibit label. This is Mr. Marentic's
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`Declaration in Support of Petition for Inter Partes
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`Review, U.S. Patent No. 7,420,550. It's previously been
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`marked as Sharp Exhibit 1007, but because it was a
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`different case, we can't use that number.
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` MR. BERKOWITZ: Great.
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` (Exhibit A, Declaration of Michael J. Marentic
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`in Support of Petition for Inter Partes Review, U.S.
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`Patent No. 7,420,550, marked for identification.)
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` MR. BERKOWITZ: I just want to object on the
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`record. This is irrelevant and outside the scope. I
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`make an objection to the exhibit that's been marked as
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`Exhibit A.
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`BY MR. HELGE:
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` Q Mr. Marentic, I've handed you what is entitled
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`"Declaration of Michael J. Marentic in Support of
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`Petition for Inter Partes Review for U.S. Patent
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`7,420,550."
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` Does this document look familiar to you?
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` A Yes, it does.
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` Q And what does it look like to you?
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` A What does it --
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` Q What does it look like to you?
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` A It looks like my declaration from the end of
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`Page 24 of 476
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`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
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`March of this year for the '550 patent that we're not
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`here to talk about today.
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` Q The cover page, Michael J. Marentic, is that
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`25
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`you?
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` A That is me.
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` Q Would you please turn to the last page, 76?
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` Is that your signature on the last page?
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` A Yes, it is.
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` Q Can I ask you to please turn to page 22 and
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`please take a moment to read paragraph 66 and 67, and
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`please let me know when you're done.
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` (Whereupon, witness reads the document.)
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`BY MR. HELGE:
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` Q Mr. Marentic, I asked you a few minutes ago,
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`have you construed terms in any other proceedings before
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`the Patent and Trial -- and Appeal Board, and your
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`answer was no.
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` Having just looked at paragraph 66 and 67, do
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`you stand by that answer?
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` MR. BERKOWITZ: Objection to form.
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` And I just want to make a standing objection
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`to relevance and outside the scope, just so I don't have
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`Conducted on October 6, 2015
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`to keep interrupting.
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` Go ahead.
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` A I believe my answer was correct that I gave to
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`you. I don't believe this is claim construction. I
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`believe construed is a more formal ruling from a court
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`that would say "Phrase A means," and then what it is.
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`BY MR. HELGE:
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` Q I'm going to read from the first sentence of
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`paragraph 67 of your declaration.
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` It states here, "I believe that 'insulated
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`with each other' means 'spaced apart from and parallel
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`to each other.'"
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` Did I read that sentence correctly?
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` A Yes, you did. There were some quotes in
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`there, but yes, those were the words in there.
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` Q So maybe there is a disconnect between what
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`I'm saying and what's in your mind.
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` How would you characterize that sentence, if
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`it's not construing a term?
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` A That's my understanding of what "insulated
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`with each other" means.
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` Q Is there a word that we can use today to
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`Conducted on October 6, 2015
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`characterize this process that you went through so that
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`we're not having a disconnect? I would call it claim
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`construction, but you don't seem to like that. So I
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`just want to know, what word can we use for today for
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`purposes of this deposition so that we understand that
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`what you've done here is what I'm talking about?
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` MR. BERKOWITZ: Objection to form.
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` A I still don't believe this is claim
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`construction in trials that I've been involved with.
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` As to a synthetic term to use, could be almost
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`anything as long as we agree that -- as to what it
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`means. I -- I was reading the patent and there was a
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`term, "insulated with each other," which is used in that
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`patent, and I said what my understanding is.
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`BY MR. HELGE:
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` Q Can we call this claim interpretation?
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` A Or my understanding.
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` Q Your understanding of what?
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` A The term insulate -- quote, insulated with
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`each other, quote, in my understanding means, quote,
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`spaced apart from and parallel to each other, close
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`quote.
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`Conducted on October 6, 2015
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` Q So is this a process for you to decide what
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`you think a claim term means?
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` MR. BERKOWITZ: Objection to form.
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` A Again, I haven't read this since March. I
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`don't have a total recall on the intricacies and
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`nuances. I'd like to review it further if we're going
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`to spend more time going over a declaration from last
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`March.
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`BY MR. HELGE:
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` Q Mr. Marentic, I'm just getting at the process
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`that you go through to understand what a claim means.
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`All we're looking for is a word to characterize that
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`process.
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` A My understanding, my experienced
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`understanding.
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` Q In your reply declaration in the '21 case, did
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`you provide any opinion on your understanding of
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`Claim 4 --
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` MR. BERKOWITZ: Objection to form.
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`BY MR. HELGE:
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` Q -- of the '843 patent?
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` MR. BERKOWITZ: Sorry to interrupt.
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`Conducted on October 6, 2015
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` Objection to form.
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` A I don't know what the '21 case is.
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`BY MR. HELGE:
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` Q That would be the case dealing with the '843
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`patent.
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` A No. I did not offer any claim construction
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`with respect to the word "generating," for instance.
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` Q What about any other terms appearing in
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`Claim 4?
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` A I don't --
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` MR. BERKOWITZ: Objection to form.
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` Go ahead.
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` A I don't believe I've construed any of the
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`claims or any of the phrases or any of the terms.
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`BY MR. HELGE:
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` Q When you prepare a declaration for a case
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`before the Patent Trial and Appeal Board, are there
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`parts of the declaration that are more important than
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`other parts?
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` MR. BERKOWITZ: Objection to form.
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`Foundation.
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` A Not that I'm aware of.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Ex. 2007
`IPR2015-00021
`Page 29 of 476
`
`
`
`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
`
`30
`
`BY MR. HELGE:
`
` Q So everything in your declaration is in there
`
`for a reason; everything's important, correct?
`
` A Correct.
`
` Q You mentioned a few minutes ago that to
`
`understand a claim term, you might look at the
`
`specification; is that right?
`
` Did I get that right?
`
` MR. BERKOWITZ: Objection to form.
`
` A The claim and the specification help me
`
`understand the patent.
`
`BY MR. HELGE:
`
` Q Is there anything else you look at to
`
`understand a patent?
`
` A From the first page to the last page, being an
`
`engineer, I like figures.
`
` Q Anything else?
`
` A No.
`
` Q You mentioned about being an engineer.
`
`Engineers seem to like procedures.
`
` Would you say that you follow the same
`
`procedure every time you're trying to understand a
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Ex. 2007
`IPR2015-00021
`Page 30 of 476
`
`
`
`Deposition of Michael J. Marentic
`Conducted on October 6, 2015
`
`31
`
`patent?
`
` MR. BERKOWITZ: Objection to form.
`
`Foundation.
`
` A I've known a lot of engineers and they're
`
`about like humans, all different. Some follow
`
`procedures and anything outside the boundary they're
`
`uncomfortable with or won't do. And other engineers are
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`just the opposite, can't get them to follow a procedure
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`if their life depended on it. So the generalization
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`that engineers are, kind of equivalent to men are or
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`women are. It's just incorrect.
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