throbber
BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`x
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`4 SNF HOLDING COMPANY,
`5 FLOPAM INC.,
`6 CHEMTALL INCORPORATED,
`7 SNF SAS, and SNF
`(CHINA)
`8 FLOCCULANT CO. LTD.,
`Petitioners,
`
`9
`
`10
`11
`
`vs.
`
`12
`13 BASF CORPORATION,
`Owner.
`Patent
`14
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`)
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`)
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`)
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`)
`
`)
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`) Case
`Patent
`
`)
`
`IPR2015-00600
`5,633,329
`
`)
`
`)
`
`)
`
`)
`
`x
`
`15
`16
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`17
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`18
`19
`20
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`21
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`22
`
`VIDEOTAPED DEPOSITION OF
`BENNY FREEMAN, PH.D., P.E.
`
`Tuesday,
`
`27, 2015
`
`October
`9:07 a.m.
`
`of Dickstein
`Law Offices
`1825 Eye Street,
`Washington,
`
`D.C.
`
`Shapiro
`
`LLP
`
`Northwest
`20006
`
`23
`24 Job No. 156549
`Reported
`by:
`
`25
`
`Lori
`
`Realtime
`
`J. Goodin,
`RPR, CLR, CRR,
`Systems Administrator
`
`EXHIBIT
`
`US LEGAL SUPPORT
`713. 653.7100
`BASF Exhibit 2003, Page 1 of 212
`SNF Holding Company et al v BASF Corporation,
`IPR2015-00600
`
`

`
`10/27/2015
`
`2
`
`I
`
`BENNY FREEMAN, PH.D., P.E.
`
`APPEARANCES
`
`For
`
`the Petitioners:
`DICKSTEIN SHAPIRO LLP
`JR., ESQUIRE
`JAMES W. BRADY,
`JONATHAN W. ENGLAND, ESQUIRE
`1825 Eye
`Street,
`Northwest
`D.C.
`20006
`Washington,
`202-420-4786
`bradyj@dicksteinshapiro.com
`englandj@dicksteinshapiro.com
`
`1
`
`2 3
`
`4
`
`5
`
`6
`
`7
`
`8 9
`
`10 For
`11
`
`12
`
`13
`
`14
`
`Owner:
`
`California
`
`94105
`
`the Patent
`REED SMITH
`JOHN P. BOVICH, ESQUIRE
`ROBERT RIDDLE, PH.D., ESQUIRE
`101 Second Street
`1800
`Suite
`San Francisco,
`415-543-8700
`jbovich@reedsmith.com
`rriddle@reedsmith.com
`
`15
`16
`17 Also Present:
`Jason Levin,
`18
`19
`20
`21
`22
`23
`24
`25
`
`CLVS
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 2 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`
`3
`
`PAGE
`
`5
`
`205
`
`206
`
`1
`
`INDEX
`BENNY FREEMAN, PH.D., P.E.
`2 WITNESS:
`3 EXAMINATION BY
`4 Mr.
`Bovich
`5 Mr. Brady
`6 Mr.
`
`Bovich
`
`EXHIBITS
`
`7 8
`
`9
`
`PREVIOUSLY MARKED EXHIBITS
`10
`11 PRIOR MARKED EXHIBIT
`FIRST REFERRAL
`1010
`28
`1007
`1009
`1011
`1001
`1012
`1002
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`61
`127
`
`130
`137
`140
`
`151
`
`(Exhibits
`
`included
`
`with
`
`the transcript.)
`
`19
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`20
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`21
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`22
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`23
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`24
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`25
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 3 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`
`4
`
`PROCEEDINGS
`
`for
`
`Holding
`
`versus
`
`al.
`
`is being
`LLP on
`Shapiro
`
`held
`
`at
`
`the
`
`the video
`THE VIDEOGRAPHER:
`is
`This
`taken by counsel
`of Benny Freeman,
`deposition
`in the matter
`the patent
`of SNF
`owner
`Company, Flopam,
`et
`Incorporated,
`the Patent
`BASF Corporation,
`before
`and Appeal Board,
`IPR Number
`Trial
`20156-00600.
`deposition
`This
`of Dickstein
`offices
`October 27, 2015.
`My name is Jason Levin,
`from U.S.
`am the video
`and I
`specialist.
`Support,
`Legal
`today is
`Goodin,
`The court
`reporter
`Lori
`Support and we are going
`from U.S.
`Legal
`the record
`at 9:07 a.m.
`counsel now please
`Will
`the record.
`appearances for
`John Bovich
`MR. BOVICH:
`BASF.
`
`also
`on
`
`state
`
`their
`
`and Rob
`
`Riddle
`
`for
`
`England
`et
`
`al.
`
`MR. BRADY:
`
`for
`
`petitioner,
`
`James Brady and John
`Company,
`SNF Holding
`
`THE VIDEOGRAPHER:
`
`And will
`
`the
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 4 of 212
`
`1
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`2 3
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`4
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`5
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`6
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`7
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`8
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`9
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`24
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`25
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`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`
`5
`
`court
`
`1
`
`2
`
`3 having
`
`follows:
`
`4
`
`5
`
`swear
`please
`reporter
`BENNY FREEMAN, PH.D.,
`sworn,
`been first
`duly
`testified
`
`in
`
`the witness.
`P.E.,
`
`EXAMINATION
`
`6 BY MR. BOVICH:
`Good morning,
`Good morning.
`You have had your deposition
`
`7
`
`8
`
`9
`
`Q.
`
`A.
`
`Q.
`
`Dr. Freeman.
`
`as
`
`taken
`
`10 before?
`
`11
`
`12
`
`13 well?
`
`14
`
`A.
`
`Q.
`
`A.
`
`Yes,
`sir.
`And you have testified
`
`in
`
`court
`
`as
`
`Yes,
`sir.
`the oath that
`You understand
`that
`the same oath that
`you
`given
`is
`you were testifying
`in
`the same penalty
`carries
`with
`it
`
`if
`
`a
`
`It
`
`is my
`That
`understanding.
`Okay.
`You understand
`21
`Q.
`22 here today to take your deposition
`you signed
`that
`23 declaration
`with
`24 et
`IPR?
`that
`25
`
`we are
`that
`the
`regarding
`to SNF,
`
`regard
`
`al.'s
`
`request
`Yes,
`
`A.
`
`for
`
`sir,
`
`is my understanding.
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 5 of 212
`
`15
`Q.
`16 you have just
`17 would give
`as
`18 courtroom.
`19 of
`perjury?
`20
`
`A.
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`1
`
`2 deposition
`
`3
`
`4
`
`5 asking
`
`Q.
`
`A.
`
`Q.
`
`for
`
`that
`
`I'm
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`10/27/2015
`
`6
`
`be
`
`form.
`do the best
`I
`and
`clearly
`as
`
`here.
`You said
`
`it
`
`Q.
`
`If
`
`you
`
`And, any reason why the
`Okay.
`forward today?
`go
`shouldn't
`aware of.
`None that
`I'm
`You understand that
`Okay.
`I will
`testimony on the questions
`your best
`you?
`asking
`MR. BRADY:
`Objection,
`I will
`THE WITNESS:
`can to answer your questions
`I can,
`completely
`as
`sitting
`MR. BOVICH: Okay.
`than I.
`better
`12
`13 BY MR. BOVICH:
`14
`
`I ever ask a
`that
`question
`ask me
`to restate
`please
`be happy to do so.
`I will
`you answer
`question,
`I'm
`you understood it.
`Do you understand
`Yes,
`you ever need to take a
`Okay.
`21
`Q.
`If
`you know, whatever,
`22 break,
`me know.
`just
`let
`be happy to accommodate you.
`23 will
`thank you.
`Okay,
`A.
`How many times have you been
`Okay.
`
`a
`
`that?
`
`sir.
`
`it,
`
`going
`
`to
`
`I
`
`understand,
`15 don't
`16 rephrase it.
`17 Otherwise,
`18 assume that
`19
`
`if
`
`20
`
`24
`
`25
`
`A.
`
`Q.
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 6 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`
`7
`
`on
`
`I'm
`
`but
`
`Q.
`
`was
`
`that
`
`2
`
`3
`
`5
`
`1 deposed before?
`know exactly.
`I
`A.
`don't
`Probably
`the order of
`20 or 30,
`round numbers,
`in
`4 not
`the exact
`sure of
`number.
`really
`those depositions,
`of
`All
`witness?
`
`6 as
`
`an expert
`
`7
`
`9
`
`Q.
`
`Objection,
`
`form.
`
`MR. BRADY:
`8 BY MR. BOVICH:
`You can answer when he does that.
`yes.
`In each case that
`I
`The --
`has always been on a,
`has
`consulting.
`It
`or
`or
`
`it
`
`legal
`
`personal
`
`criminal
`
`A.
`10
`11 have been at
`deposition,
`12 I would say matter
`of
`13 never been on anything
`that.
`14 anything
`like
`Okay.
`
`Have these all
`
`been patent
`
`15
`
`Q.
`
`16 matters?
`
`17
`
`A.
`
`18
`Q.
`19 what percent
`20 matters?
`I
`A.
`don't
`21
`22 counted them up, but
`know.
`I
`23 But,
`don't
`just
`sitting
`24 figure
`25 back at my
`
`records.
`
`No,
`sir.
`you know,
`Okay.
`roughly,
`About,
`of
`them would you say were patent
`
`probably
`
`know exactly.
`I
`haven't
`more than half.
`you a complete
`give
`I would have to look
`
`I
`
`can't
`
`here.
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 7 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`1
`
`3
`
`4
`
`Okay. What
`of
`kind
`Q.
`2 keep that would help
`you answer
`MR. BRADY:
`THE WITNESS:
`
`Objection,
`
`Well,
`
`10/27/2015
`
`8
`
`of
`
`list
`
`records do you
`that
`question?
`form.
`I keep a
`I keep files
`and invoices.
`billing
`I would say.
`
`24
`
`25
`
`Objection
`I
`
`am,
`
`to form.
`am working
`
`I
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 8 of 212
`
`like
`
`records,
`
`You know that
`
`start
`
`this
`
`this
`currently,
`over.
`that
`an IPR?
`
`is
`
`IPR is?
`
`an
`
`It
`
`relatively
`
`new
`
`I
`
`as
`far
`Okay.
`conjunction
`I
`
`may
`
`be
`
`have you been
`
`5
`
`6
`
`9
`
`12
`
`13
`
`14
`
`my
`
`A.
`
`Q.
`
`A.
`
`15 understanding
`
`16 process,
`
`as
`
`17
`Q.
`18 deposed in
`A.
`19
`20 time,
`21
`Q.
`22 been retained
`23 this
`particular
`
`as
`
`far
`
`activities.
`consulting
`to things
`related
`Those sorts
`of
`7
`8 BY MR. BOVICH:
`Okay.
`Q.
`10 what we are here --
`let
`me
`You know that
`11
`Yes,
`sir.
`You know what an
`I have --
`I
`am developing
`is a
`of
`it.
`understand.
`How many times
`an IPR?
`with
`the,
`the first
`think
`this
`now.
`I can recall
`right
`as
`And how many times have you
`Okay.
`regard to an
`IPR other
`with
`than
`matter?
`MR. BRADY:
`THE WITNESS:
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`
`9
`
`1
`
`2
`
`3
`
`4
`
`5
`
`currently
`
`separate
`
`deposed in
`think
`that
`
`on one other
`
`matter
`
`a
`
`is
`
`related
`
`--
`
`that
`in
`is
`to an IPR.
`that
`field
`I have not
`I have not been
`given
`at
`But
`I
`that
`this
`matter
`point.
`the only other one that
`can
`
`is
`
`I
`
`for
`
`owner.
`
`small
`
`businessman
`
`with
`
`a
`
`is
`
`the field
`
`that
`
`you are
`
`recall.
`7 BY MR. BOVICH:
`are you working
`In that
`matter,
`the patent
`or
`owner?
`the patent
`case,
`In that
`for
`the patent
`owner?
`And who
`is
`named Richard
`fellow
`is a
`Interfex.
`And what
`
`6
`
`8
`
`9
`
`10
`
`11
`
`12
`
`Q.
`the petitioner
`A.
`
`Q.
`
`A.
`
`It
`
`is
`
`a
`
`And he
`13 Callahan.
`14 company called
`15
`
`Q.
`on?
`
`16 opining
`
`17
`
`18
`
`scope.
`
`MR. BRADY:
`
`Objection.
`
`Outside
`
`the
`
`THE WITNESS:
`gas purification
`natural
`membranes.
`21
`22 BY MR. BOVICH:
`Your prior
`Okay.
`23
`you can give
`ballpark
`me
`a
`you have been retained
`percent
`
`19
`
`20
`
`Q.
`
`24 roughly,
`if
`to what
`
`25 as
`
`This
`
`is in the area of
`polymer
`using
`
`depositions,
`
`just
`
`estimate
`on
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 9 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`10
`
`the patent
`of
`owner versus
`a
`remember exactly.
`I
`A.
`don't
`by counsel
`I have been retained
`owners as well
`as
`folks
`defending
`you know, against
`
`defendant.
`
`But,
`
`I
`
`for
`
`both
`
`of
`
`accusations
`
`behalf
`
`1
`
`2
`
`3 have,
`4 patent
`
`5
`
`6
`
`7
`
`themselves,
`
`infringement.
`
`Q.
`
`17 in
`
`18 this
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`8 on either
`9 work versus
`10 around?
`A.
`11
`12 the other.
`13 direction
`
`14 tell
`
`15
`
`16 retained
`
`side,
`
`is higher
`Would you say the number
`you have done more patent
`owner
`the other
`work or
`way
`defendant's
`
`I,
`
`It
`
`tell
`
`enormously
`
`But,
`
`I
`
`you one way or
`skewed in
`one
`I
`couldn't
`don't,
`
`Petitioners
`
`other
`
`than
`
`I
`couldn't
`is not
`the other.
`or
`you the exact
`figure.
`Okay.
`Have you been
`right.
`Q.
`All
`the other
`by SNF or any of
`on any other matters
`this
`matter
`case?
`
`MR. BRADY:
`THE WITNESS:
`I had some
`an earlier
`SNF.
`
`exactly.
`
`an
`
`earlier,
`
`involving
`
`Objection
`I
`
`don't
`
`discussions
`
`to form.
`recall
`
`related
`
`matter
`
`in,
`
`that
`
`to
`was
`
`I never wrote any reports
`But,
`deposed or was deposed or
`anything
`like
`
`or
`that.
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 10 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`11
`
`1
`
`And I,
`
`frankly,
`
`remember
`don't
`agreement or,
`
`I
`if
`signed
`a
`you know, even
`
`stage.
`
`confidentiality
`got
`to that
`4 BY MR. BOVICH:
`Okay.
`owner?
`patent
`remember enough about
`I don't
`A.
`8 know the answer
`to that
`question.
`Did the matter
`Okay.
`Q.
`reactors?
`
`2
`
`3
`
`5
`
`6 was
`
`a
`
`7
`
`9
`
`10 polymer
`11
`12 polymer
`13 reactors,
`
`Q.
`
`Was
`
`that
`
`a matter
`
`where SNF
`
`it
`
`to
`
`involve
`
`A.
`
`gels.
`
`It
`
`involved,
`I don't
`
`it
`
`recall
`
`involved
`if
`
`it
`
`polymer,
`
`involved
`
`specifically.
`Okay.
`Q.
`me back up.
`
`14
`
`15 let
`
`Have you been retained
`
`by --
`
`all
`
`that
`
`the petitioners
`of
`terminology?
`
`I
`call
`16
`If
`17 SNF, are you okay with
`Yes,
`A.
`that
`fine.
`is
`Okay.
`Have you been retained
`on any other
`his
`firm
`before
`
`18
`
`19
`Q.
`20 Mr. Brady or
`21 matters?
`
`22
`
`A.
`
`23
`Q.
`24 can do it
`A.
`
`25
`
`at
`
`by
`
`I have.
`And describe
`
`Yes,
`Okay.
`level.
`high
`a
`There was,
`
`them to me.
`
`You
`
`I did some work with
`
`them
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 11 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`infringement
`1 on patent
`2 coronary artery
`Q.
`
`involving
`drug-eluting
`a
`some years ago.
`stent
`And who was Mr. Brady's
`
`client
`
`3
`
`that
`
`4
`
`matter?
`
`10/27/2015
`12
`
`in
`
`5
`
`was
`
`an
`
`individual
`
`patent
`
`owner,
`
`A.
`It
`6 Dr. Bruce Saffran.
`the only time that
`you have
`Is that
`by Mr. Brady or his
`colleagues,
`to this
`previous
`matter?
`Yes.
`I can recall
`A.
`far
`as
`10
`sitting
`As
`the only one
`the,
`11 here today,
`is
`that
`of.
`12 can,
`I can think
`I asked you the same
`And,
`Okay.
`13
`if
`to the Dickstein
`regard
`with
`Shapiro
`the same answer?
`would you keep giving
`me
`to make sure I cover my bases in my
`
`7
`
`Q.
`8 been retained
`9 previously
`
`--
`
`Q.
`
`14 question
`
`15 firm,
`I want
`17 question.
`
`16
`
`that
`
`is
`
`I
`
`18
`
`19 give
`
`24 patent
`
`25
`
`I
`A.
`understand.
`you the same answer.
`In the Saffran
`Okay.
`20
`Q.
`of
`the patent
`21 you working
`on behalf
`22 accused infringer?
`In that
`A.
`23
`owner.
`Q.
`
`Yes,
`
`sir,
`
`I would
`
`were
`matter,
`owner or
`an
`
`was
`
`the
`
`case, Dr.
`
`Saffran
`
`Okay. Okay.
`
`Have you given
`
`expert
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 12 of 212
`
`

`
`6
`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`13
`
`testimony
`
`1
`
`before
`
`on any matters
`
`involving
`
`2 polymerization
`
`A.
`
`Q.
`
`the form.
`
`reactors?
`goes back a while.
`No rush.
`
`It
`
`So,
`
`I'm
`
`--
`
`MR. BRADY:
`
`I'm
`
`going
`
`to object
`
`to
`
`THE WITNESS:
`
`I have given,
`other,
`in
`testimony
`in
`to polymers and,
`formats.
`
`in
`
`given
`
`expert
`
`related
`matters
`of different
`
`I have
`legal
`a number
`
`I
`
`don't
`
`recall
`
`that
`
`focused
`
`exclusively
`
`reactors.
`
`It
`
`is,
`
`specifically
`on polymerization
`you know, often
`as
`a number of
`issues
`the way.
`I have been,
`certainly
`where polymerization
`and how that
`issue,
`
`a matter
`
`in
`
`that
`
`these
`are,
`
`been
`of
`occurred,
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`matters
`
`that
`
`there
`is
`come up along
`And so,
`deposed in matters
`was at
`products
`and so
`forth.
`19
`20 BY MR. BOVICH:
`Have you given
`21
`Q.
`22 on any matters
`before
`involving
`
`any expert
`testimony
`the design
`of
`
`23 polymerization
`
`reactors?
`
`24
`
`25
`
`MR. BRADY:
`THE WITNESS:
`
`Objection,
`I don't
`
`form.
`believe
`
`I have
`
`US LEGAL SUPPORT
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`BASF Exhibit 2003, Page 13 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`14
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`8
`
`offered
`
`involving,
`
`reactors
`
`Q.
`
`the matters
`polymerization
`
`--
`
`I
`think
`And I want
`as
`an
`expert
`
`was
`question
`last
`my
`you
`to ask you if
`on any matters,
`the design
`
`matter,
`
`involving
`
`of
`
`opinions
`in
`specific
`where I can recall
`used.
`being
`at which they were
`The conditions
`used informed my opinions
`on other
`being
`aspects of
`the matters,
`so
`7 BY MR. BOVICH:
`Okay.
`
`9 about
`testimony.
`10 have been retained
`11 other
`than this
`12 polymerization
`
`reactors?
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`projects
`
`involve
`and then
`
`indirectly
`
`20
`
`21
`
`22
`
`Objection,
`
`the
`
`polymers,
`
`least
`
`form.
`MR. BRADY:
`many of
`THE WITNESS:
`Again,
`I have worked on involve,
`that
`polymers and manufacture
`of
`use of
`polymers.
`they would at
`And so,
`involve
`reactors.
`polymerization
`a case where I have
`about detailed
`design
`those topics
`are often
`I have worked on.
`that
`
`I
`can't
`recall
`been asked specifically
`of
`reactors,
`although
`at
`the matters
`23
`in
`issue
`24 BY MR. BOVICH:
`Can you recall
`25
`
`Q.
`
`any matter
`
`where the
`
`US LEGAL SUPPORT
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`BASF Exhibit 2003, Page 14 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`15
`
`of
`A.
`
`1 design
`
`2
`
`3
`
`4 Other
`
`5
`
`7
`
`a polymerization
`Yes,
`Okay.
`Q.
`than this
`matter.
`Yes,
`A.
`6 done consulting
`for
`the manufacture
`of
`8 which are polymer
`9 and reactors
`typically
`
`reactor
`
`was at
`
`issue?
`
`you explain
`
`that
`
`to me?
`
`sir.
`
`Can
`
`sir.
`
`So,
`
`patent
`
`extended
`
`gels
`
`that
`
`called
`
`I have done,
`I have
`involving
`litigation
`wear contact
`lenses,
`are UV polymerized,
`molds,
`the
`for
`
`10 lenses.
`
`11
`
`Q.
`
`was
`12 matter,
`13 the mold?
`A.
`14
`
`Okay.
`there
`
`And in
`an issue
`
`that
`about
`
`particular
`the design of
`
`in
`
`in
`
`is
`
`it
`
`optical
`
`characteristics
`In that
`
`matter,
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 15 of 212
`
`those
`Yes.
`The mold does,
`a number of
`is
`One
`functions.
`serves
`15 reactors,
`sets the power
`sets the mold shape,
`and design
`16 it
`the lens.
`the walls
`sets the
`17 of
`of
`The material
`the way lenses
`the gel,
`are formed
`of
`18 adhesion
`19 and how easy they are to remove.
`at which the
`The conditions
`20
`in basically
`run affects
`is
`the final,
`the final
`product,
`hazy, has the right
`clear,
`you want.
`that
`the issue
`what was
`
`21 polymerization
`
`22 properties
`
`23 whether
`24 and other
`25
`
`Q.
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`16
`
`you were asked to opine on?
`1 about mold design
`these
`how the design
`of
`A.
`Essentially
`oxygen and water
`affecting
`the materials.
`through
`transport
`And as
`5 shape and size
`and polymerization
`conditions
`changes the rate
`at which
`6 change,
`changes,
`it
`it
`through the final
`7 oxygen and water
`go
`product.
`there any issue
`Okay. What, was
`Q.
`the design
`though?
`of
`the mold,
`itself,
`form.
`MR. BRADY:
`Objection,
`The,
`THE WITNESS:
`particular
`or
`of matters
`series
`broad based.
`And it
`quite
`aspects of polymer
`design
`those,
`how those materials
`And the preparation
`of
`polymerization.
`
`the mold
`
`that
`
`was
`
`actually,
`covered many
`how
`as well
`as
`were prepared.
`the
`them involved
`
`2
`
`3 materials
`
`was
`
`4
`
`8
`
`9 about
`10
`
`matter,
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`that
`
`was
`
`So,
`it
`one of
`
`that
`
`20
`
`24 that
`
`25
`
`considerations
`the patents
`21
`22 BY MR. BOVICH:
`the issue
`What was
`23
`Q.
`you were asked to opine
`on?
`My work there
`A.
`
`involve
`
`because
`that,
`did
`the,
`the
`one of
`that
`was
`in making these things,
`and in
`were in
`suit.
`
`about mold design
`
`was
`
`primarily,
`
`was
`
`US LEGAL SUPPORT
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`BASF Exhibit 2003, Page 16 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`17
`
`to the,
`how the mold design affected
`the
`shape and dimensions.
`And then
`how
`lens
`final
`that would influence
`the transport
`of water and
`those materials.
`4 oxygen through
`Have you ever
`polymerization
`Yes,
`Okay.
`there.
`
`participated
`reactor?
`
`in
`
`the
`
`sir.
`
`And tell
`
`me about your
`
`related
`
`1
`
`2
`
`3
`
`5
`
`6 design
`
`7
`
`8
`
`9 experience
`
`a
`
`Q.
`of
`A.
`
`Q.
`
`10
`
`11 first,
`
`A.
`
`other
`
`well,
`
`this
`
`a
`
`focused
`
`polymerization,
`
`school
`
`in
`
`that
`
`research,
`at
`that
`by free
`were,
`and so
`
`that
`
`reaction,
`
`I would say the
`the --
`So,
`I,
`than studying
`in school
`to this
`first
`12 theoretically,
`exposure
`direct
`my
`to graduate
`13 came when I, when I got
`in
`14 chemical engineering.
`And my
`thesis
`area of
`research
`active
`15 fact,
`fairly
`16 time was
`on how to polymerize,
`radical
`materials
`17
`heats of
`18 had high
`exothermic
`19 they would tend to run away.
`People at
`the time were normally
`20
`21 making these
`like
`poly
`methyl
`materials,
`and polystyrene,
`22 methacrylate
`23 to control
`this
`runaway.
`24 thermal
`We were,
`
`in
`
`batch
`
`so-called
`
`gel
`
`effect
`
`reactors
`the
`
`or
`
`25
`
`I was
`
`part
`
`of
`
`a group that
`
`US LEGAL SUPPORT
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`
`

`
`how to make these materials
`reactors.
`tubular
`the beginnings
`of my, of my
`And so
`were focused
`and
`on operating
`experience
`how to operate existing
`and learning
`we had in the lab
`to
`and starting
`that
`reactors
`around the polymerization
`processes
`7 do modeling
`were going
`that
`on inside
`these.
`so,
`was my, my earliest
`that
`My
`the laboratory.
`to interrupt
`you and ask a
`going
`I'm
`I know you are not done.
`And I'm
`but
`you continue with
`your answer
`to let
`is
`complete.
`Okay.
`The words you just
`involve
`designing
`
`13 going
`
`14 record
`
`15
`
`A.
`
`Q.
`
`that
`
`so
`
`the
`
`testified
`
`of
`
`reactors
`
`did
`
`to,
`
`that
`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`18
`
`in
`
`the
`
`1 was
`
`studying
`2 continuous
`
`3
`
`4 Ph.D.
`5 using
`
`6
`
`8
`
`9
`
`10 experience
`
`in
`
`11
`
`Q.
`
`12 question,
`
`--
`
`16
`17 any of
`18 didn't
`
`19
`
`exist?
`the beginning
`At
`of my
`changing
`we were, we were looking
`20 research,
`into
`21 the reactor
`because we had problems with
`design
`22 the version,
`the previous
`would often
`version
`And when these things
`got
`23 plugged.
`plugged,
`24 you had to take it
`cases
`and some
`all
`apart,
`out
`the material
`the reactor.
`from inside
`25 drill
`
`already
`
`A.
`
`thesis
`
`get
`then
`
`US LEGAL SUPPORT
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`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`19
`
`1
`
`2 we could modify
`3 of
`that
`times
`
`4
`
`5 modify
`
`Q.
`
`it?
`
`at ways that
`And so we were looking
`the design
`the number
`to minimize
`I would get
`to take it
`apart.
`And what were the ways to
`Okay.
`
`at changing,
`Two.
`A.
`looked
`We
`7 changing the dimensions of
`the reactor.
`at
`on the temperature
`the
`looked
`backing
`off
`so
`go,
`have as much of
`9 polymerization
`didn't
`didn't
`to get out of
`you get
`if
`opportunity
`control,
`hot spot or
`the
`a dead zone inside
`
`We
`
`We
`
`looked
`
`Changing
`in with
`things
`that
`
`at changing the level
`of
`the level
`of
`that
`solvent
`the monomers.
`Those were very
`one could vary
`to slow things
`
`6
`
`8
`
`10 an
`
`11 a
`
`local
`
`12 reactor.
`
`13
`
`14 initiators.
`
`15 was
`
`going
`
`16 typical
`17 down --
`
`18
`
`19
`
`Q.
`
`A.
`
`20 gel,
`
`gel
`
`21 material
`
`--
`
`particle,
`
`plugging
`
`and
`
`integrated
`
`thermal
`
`Okay.
`and help
`eliminate
`you know,
`so
`forth.
`I
`
`formation,
`Okay.
`So,
`you continue
`
`22
`Q.
`23 wanted to let
`24 previous
`experiments
`
`you.
`interrupted
`your answer about
`experience
`with
`reactor
`
`I
`
`--
`
`25 design.
`
`US LEGAL SUPPORT
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`
`

`
`10/27/2015
`20
`
`to
`
`BENNY FREEMAN, PH.D., P.E.
`
`A.
`to that.
`school,
`to do that
`factors
`5 an undergraduate
`working
`at
`And I worked rotations
`
`So,
`
`--
`
`you a more complete
`to give
`just
`I went
`I
`before
`well,
`also
`the motivating
`and one of
`three summers as
`I spent
`was
`a DuPont polyester
`in
`different
`
`1
`
`2 answer
`3 graduate
`
`4
`
`6 plant.
`
`7 departments.
`
`8
`
`The last
`9 continuous polymerization
`And, so,
`10
`at modifying
`the plant
`
`11 was
`looking
`at
`12 process
`13 throughput.
`
`in
`of
`
`the
`of which was
`that
`section
`plant.
`a group that
`I was helping
`the polymerization
`to increase,
`increase
`
`the
`
`there these were,
`And so,
`this
`was
`scale industrial
`making
`facility
`at
`10,000 pounds an
`something
`like
`three different
`reactors.
`So,
`in
`those reactors?
`In other words,
`
`a
`
`very
`
`general
`
`way,
`
`can you
`
`let's
`
`start
`
`out with
`
`full
`
`14
`15 a, at
`16 polyester
`
`17 hour,
`
`a
`
`in
`
`18
`
`Q.
`
`19 describe
`
`20
`21 the shape.
`A.
`22
`
`Sure.
`the raw materials
`So,
`the polymerizations,
`it
`23 stored
`for
`in,
`24 condensation polymerization
`to make the
`And,
`the raw materials
`25 polyesters.
`so
`
`were
`
`is
`
`a
`
`were
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 20 of 212
`
`

`
`that
`a waste
`case
`
`they were,
`was
`
`--
`
`that
`
`polymerization,
`
`unlike
`
`bottom tanks,
`in
`1 stored
`essentially,
`2 were heat
`on a waste section,
`or
`traced
`tank in
`case --
`waste line
`pond in
`line
`there was
`And those were outside.
`spill.
`And then inside
`we had a
`which was
`reactor
`6 prepolymerization
`there were three lines
`in the train
`at
`8 operating
`particular
`this
`plant.
`And the prepolymerization
`reactors
`tapered bottom to
`and they had this
`10 were conical,
`And these were used to carry
`the
`11 them.
`up to a
`certain
`12 polymerization
`point.
`In polyester
`13
`14 other
`types of
`an
`polymerization,
`is
`there
`formed.
`You combine monomers to make
`15 equilibrium
`and then polymers.
`But you get
`low
`out of
`molecule
`weight
`that
`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`21
`
`flat
`
`a
`
`3
`
`4
`
`5
`
`7
`
`9
`
`16 oligomers,
`
`17 molecular
`
`kicked
`
`a
`
`18 reaction.
`
`19
`
`20 Le Chatelier's
`21 and you can't
`22 higher.
`
`And so at
`the
`some
`with
`point
`you form an equilibrium
`principle,
`the molecular
`any
`weight
`
`drive
`
`And so we reached that
`23
`24 these prepolymerization
`reactors.
`fed into
`25 material
`was
`then
`
`point
`And the
`essentially
`
`a,
`
`in
`
`a
`
`large
`
`US LEGAL SUPPORT
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`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`22
`
`1 extruder
`
`2
`
`3
`
`injectors
`4 water,
`in
`some
`
`5
`
`reaction.
`
`6
`
`7 by-product,
`
`a vacuum.
`under
`operating
`And we used, at
`steam
`that
`plant,
`the
`to create
`the vacuum, and pull
`off
`was water or
`the by-product.
`that
`was
`It
`cases methanol
`the by-product
`of
`that
`was
`you removed that
`And if
`small
`molecule
`towards
`the equilibrium
`shifts
`
`that
`
`8 high
`
`polymer.
`
`9
`
`10 molten
`
`state
`
`11 material
`
`that
`
`12
`
`film
`
`formation,
`
`13 application
`
`14
`
`Q.
`
`15 polymerization,
`
`A.
`16
`17 occurred --
`18 And you start
`19 reactors
`that
`
`20 extruder.
`
`21 higher
`
`22 apply
`
`it
`
`you could, and then in
`And so,
`make a
`high
`molecular
`weight
`then went
`to extrusion
`was,
`and then ultimately
`into
`we were working
`on.
`the
`Does
`that
`mean that
`occurred in
`the extruder?
`itself,
`Some of
`Some of
`it
`did.
`there is
`a prepolymerization
`the reaction
`these conical
`in
`then feed the,
`feed the
`that
`you carry the reaction
`to
`And then
`the extruder,
`where you can
`in
`conversion
`and get
`a vacuum, and get
`a better
`mixing,
`condensation products
`these small
`23 this,
`molecule
`the material.
`24 out of
`That
`how you drive
`it
`is
`25 high
`molecular
`weight.
`
`the
`
`and
`the
`
`step.
`
`to
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 22 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`23
`
`1
`
`Q.
`
`How was
`
`2 prepolymerization
`
`3
`
`6
`
`9
`
`A.
`
`Q.
`
`but
`
`We
`
`10 conical,
`
`and
`
`moved from the
`the material
`the extruder?
`reactors
`in
`It would,
`it would flow.
`We had it
`has
`I
`by nitrogen,
`4 pressurized,
`believe,
`it
`5 been more than 30 years ago now.
`But
`it was,
`pressurized.
`it
`was
`these tanks to
`had pumps at
`the bottom of
`7 also
`the extruder.
`8 help move that
`material
`into
`these reactors
`Were
`entirely
`or were they partially
`tubular
`The prepolymerization
`conical?
`
`11 partially
`12 reactors?
`We may need to get our, make sure we
`A.
`13
`14 are on the same page on the nomenclature.
`Okay.
`15
`Q.
`The,
`just
`
`we,
`
`if
`
`16
`
`17 conical
`
`A.
`
`is
`
`a
`
`so, by --
`cylinder?
`
`okay if
`it
`is
`And, well
`I mean non-parallel
`
`--
`
`18
`
`19 walls.
`
`Q.
`
`By
`
`conical,
`
`20
`
`21
`
`22
`
`23
`
`reactors
`
`MR. BRADY:
`Objection
`THE WITNESS: Okay.
`they had a
`were,
`portion
`just
`cylinder
`that
`was
`end of
`them.
`24
`25 BY MR. BOVICH:
`
`to form.
`the
`So,
`was,
`that
`a cone on the
`
`a
`
`with
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 23 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`24
`
`And there was
`Okay.
`different
`a
`Is that
`what
`to understand
`too?
`2 portion,
`I'm
`3 your use of
`the word,
`portion?
`top and then a
`they had a
`A.
`Well,
`fed an outlet
`a cone that
`and then
`And then, and then, you know, downstream
`valve.
`7 pumping and the extruder.
`Have
`Okay. Okay.
`right.
`All
`Q.
`Have you
`I want
`about
`to be fair
`9 you --
`this.
`10 completed your answer
`broad question
`to my pretty
`11 about prior
`reactors?
`designing
`experience
`those were the first,
`A.
`So,
`12
`13 two cases that
`I can remember.
`I work in
`the area of
`14
`the material
`and in
`science
`
`Q.
`
`1
`
`4
`
`5 cylinder
`
`6
`
`8
`
`15 so we --
`
`16 polymers.
`
`by
`
`the first
`
`and
`polymers,
`aspects of
`
`17
`
`18 materials.
`
`19 reactions
`
`in
`
`basis,
`
`20 daily
`
`21 in
`
`22 So,
`
`23
`
`24 consultant
`25 polymer
`
`in making new
`And so we are involved
`And so we carry out polymerization
`our
`on a
`laboratory
`practically
`and have for
`I have been
`as
`long
`as
`on the order of 25,
`this
`26
`years.
`business,
`there is
`that
`experience.
`been, have served as
`I have also
`are involved
`to companies
`that
`in
`polymer manufacture,
`and have
`processing,
`
`a
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 24 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`25
`
`1 certainly
`reactors
`2
`3 and this
`
`Q.
`5 main area of
`through
`polymer
`
`4
`
`6
`
`of how the
`work better
`
`to form.
`the output
`from
`of course
`is,
`and patents.
`focus
`
`mainly
`
`on
`
`in discussions
`been involved
`worked and how they might
`of
`thing.
`sort
`your
`Would you agree with
`that
`me
`the passage of molecule
`expertise
`is
`membranes or plastics?
`MR. BRADY:
`Objection
`The,
`THE WITNESS:
`research program,
`primarily
`students,
`publications,
`And the publications
`mass
`transfer
`in
`polymers.
`the transport
`of
`small
`ions,
`and so
`through
`forth
`liquids,
`Often through
`polymers that
`are going
`to be used in
`that
`separation
`membranes,
`sometimes as,
`in
`packaging.
`
`our
`it
`
`is
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`And so
`
`molecules
`
`like
`
`this
`
`is
`gases,
`polymers.
`are,
`
`barrier
`
`And, so, our, our end product
`is
`around new materials
`these types of
`for
`of
`and testing
`applications,
`existing
`
`often
`
`materials.
`
`relation
`
`polymers
`
`the
`of
`And as
`part
`understanding
`those
`between the structure
`of
`and their
`properties,
`some materials
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 25 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`26
`
`for
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`Others
`
`we have to
`And we
`how they
`how to
`
`both
`
`results
`
`we get
`
`for
`
`all
`
`of
`
`polymerization
`
`these reasons,
`and
`
`we
`
`Although
`
`is
`
`that
`
`our
`focused
`we can
`applications.
`
`on
`
`we have to make ourselves.
`get
`from industrial
`collaborators.
`always have to understand
`typically
`are made in order
`to understand
`interpret
`their
`properties
`properly
`downstream.
`And so, we have to be familiar,
`our own work,
`as,
`as well
`as
`how to interpret
`understanding
`on commercial materials.
`And we are engineering
`scientists.
`And so, we also
`to be aware of how
`like
`are made and processed
`materials
`in
`industry,
`because as we are doing
`on different
`research
`types of materials,
`we would like
`to be doing
`research that
`and could be
`can be
`scaleable
`when the
`to industry
`when the,
`translated
`time came.
`And so
`are, we study
`reactors.
`polymerization
`research output
`papers,
`our
`making these materials
`so
`them for
`characterize
`24
`25 BY MR. BOVICH:
`
`other
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 26 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`27
`
`also
`
`the
`
`the main focus
`And,
`of
`Q.
`of your
`the passage of
`is
`research
`these materials;
`through
`that
`is
`right?
`That has been a,
`has been a
`that
`I have worked on since
`I was an
`a, and so,
`researcher.
`And it
`is
`is where most of our
`publications
`
`1
`
`2 output
`
`3 molecules
`
`4
`
`5
`
`topic
`
`A.
`
`that
`
`6 undergraduate
`
`7 certainly,
`8 are focused.
`
`that
`
`9
`
`Q.
`
`--
`
`the primary
`And
`that
`topic
`is
`the Freeman Research Group or
`10 of
`it
`is
`11 Freeman Group?
`the exact
`name.
`I
`forget
`is --
`one is
`A.
`either
`12
`
`It
`
`well,
`
`focus
`the
`
`fine.
`
`13 So --
`
`Q.
`
`14
`
`17
`
`Okay.
`who come out of our
`Most of
`the kids
`A.
`15
`in their
`16 group will
`as an endpoint
`be working
`to design
`and
`relate
`thesis
`on topics
`that
`of new desalination
`membranes,
`18 characterization
`19 new gas separation
`membranes,
`new barrier
`membranes.
`20 packaging
`have to, have
`them will
`Most of
`also
`21
`the,
`those polymers as
`some of
`22 to make
`of
`part
`as
`the process of
`to understand
`of
`23 part
`being
`able
`24 the relation
`between the structure
`and properties.
`going to hand you your CV.
`Okay.
`25
`I'm
`Q.
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 27 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`28
`
`1
`
`2
`
`3
`
`4
`
`Thank you.
`MR. BRADY:
`(Whereupon,
`previously
`SNF Exhibit
`
`1010
`
`first
`
`referral.)
`
`marked
`
`5 BY MR. BOVICH:
`this
`So,
`SNF Exhibit
`is
`the record,
`can you verify
`just
`for
`the CV that
`you provided
`on
`this
`checked it
`I
`A.
`haven't
`way.
`sure looks
`that
`Did you prepare this
`case?
`No,
`So,
`current
`
`6
`
`7
`
`8
`
`9
`
`it,
`
`10 but
`11
`
`12 for
`
`this
`
`13
`
`Q.
`
`it
`
`Q.
`
`A.
`
`14
`
`15 is
`
`Q.
`the most
`16 purposes,
`is
`
`17
`
`A.
`
`18 current
`
`version.
`
`And
`
`is
`
`1010.
`that
`this
`case?
`exhaustively,
`
`CV especially
`
`sir,
`
`it
`
`that
`No.
`
`a
`
`It
`
`is
`
`I did
`not.
`the same CV that
`you use for
`CV that
`fair
`statement?
`is not,
`
`it
`
`is not
`
`you --
`
`it
`
`all
`
`the most
`
`the most
`Okay.
`19
`it
`Was
`Q.
`20 the day it was,
`you provided
`that
`it
`it would have been,
`To,
`A.
`21
`22 of my ability.
`23
`
`Q.
`
`24 question.
`25 day on this.
`
`I'm
`
`Okay.
`not
`
`So,
`
`going
`
`level
`high
`is
`this
`very
`a
`to ask you to spend all
`
`as of
`current
`to counsel?
`to the best
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 28 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`29
`
`1
`
`2 publications,
`
`3 exhaustive
`
`list.
`
`4 every
`
`publication
`
`5
`
`6
`
`in
`
`here that
`7 design?
`
`I'm
`
`at your
`you look
`if
`But,
`can you point
`this
`not
`is
`me --
`not
`you to identify
`asking
`answers my question.
`that
`But can you point
`me to any articles
`focus
`on the subject
`of
`reactor
`
`an
`
`Objection,
`
`is
`
`some
`
`that
`
`thesis,
`
`fundamental
`problems
`
`in
`
`a
`
`collaboration
`out at Walnut
`facility.
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 29 of 212
`
`form.
`MR. BRADY:
`the,
`the,
`THE WITNESS:
`there
`So,
`towards the,
`towards the end, where,
`were publications
`from my, my Ph.D.
`364, and some others below that.
`like
`of
`when I
`studies
`started
`my
`But,
`these polymerization
`reactors,
`on some more fundamental
`focused
`the plugging
`were driving
`of
`And so, papers
`the reactors
`about
`specifically.
`aimed at
`a more, at
`that
`giving
`was
`really
`the reactors.
`of
`done in
`366 and 367 were projects
`from Dow Chemical
`with
`folks
`the Walnut
`Creek
`Creek,
`
`I
`
`like
`
`it
`
`is
`
`ultimately
`issues that
`these materials.
`364 don't
`talk
`But
`problem
`the design
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`30
`
`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
`
`And they were new into
`the area of
`making polymers for membranes and making
`those.
`And so these
`for
`hollow
`fibers
`those fibers
`focused
`on
`spinning
`the reactor.
`had exited
`a number of
`them in
`There is
`where synthesis of materials
`in
`are described,
`polymerization
`reactors
`
`here
`
`often
`
`publications
`
`after
`
`they
`
`that,
`
`you
`
`And
`
`in
`
`significant
`
`detail.
`Any time you make new materials,
`have to,
`one of
`the standards
`of
`publishing
`means you have to describe
`what you did.
`you have to
`you make new materials,
`if
`how you made it.
`describe
`there is
`And, so,
`over 100 of
`them that
`talk
`and the types of
`polymers,
`use.
`
`a
`
`well
`probably
`about how we make
`reactors
`that
`we
`
`--
`
`by the time
`They don't
`typically
`to publication,
`you get
`you are not,
`you are
`not describing
`every step or
`you
`iteration
`went
`to design
`the reactor
`you
`through
`used.
`
`that
`
`The page limits
`articles
`don't
`
`journal
`
`and so
`that.
`
`permit
`
`forth
`
`on the
`But you
`
`US LEGAL SUPPORT
`713.653.7100
`BASF Exhibit 2003, Page 30 of 212
`
`

`
`BENNY FREEMAN, PH.D., P.E.
`
`10/27/2015
`31
`
`1
`
`2
`
`are presenting
`at
`effort
`
`the,
`
`what was your
`your,
`to make the materials
`
`best
`you were
`
`3
`
`after.
`4 BY MR. BOVICH:
`Can you point
`me
`you just
`not
`asking
`
`5
`
`6
`
`7
`
`Q.
`types of
`publications
`answer?
`last
`8 exhaustive
`list.
`
`Again
`
`few of
`to a
`mentioned
`
`the
`your
`in
`
`I'm
`
`for
`
`an
`
`A.
`over
`
`Sure.
`period
`
`a
`
`if
`
`me take
`
`I
`
`9
`
`10 several
`
`11
`
`12 synthesis
`13 1993.
`14 started
`
`15
`
`16 in
`
`18
`
`our
`17 polymerizing
`
`lab
`
`you --
`So,
`let
`time and --
`of
`354 describes
`So,
`polymer
`some
`in about
`work,
`that
`starting
`is
`so
`Those are among the first
`publications
`to get out
`a young faculty
`membe

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