`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` OWENS CORNING )
` )
` Petitioner, )
` )
` VS. ) Case IPR2015-00650
` ) Patent 8,137,757 b2
` FAST FELT CORPORATION )
` )
` DEFENDANT )
` )
` )
` )
` )
`********************************************************
`
` ORAL DEPOSITION OF
`
` DR. MARK BOHAN
`
` February 4, 2016
`
` Volume 1
`
`********************************************************
` ORAL DEPOSITION OF DR. MARK BOHAN, produced as a
`witness at the instance of the PETITIONER, and duly
`sworn, was taken in the above-styled and numbered cause
`on February 4, 2016 from 9:43(cid:160)a.m. to 5:50(cid:160)p.m., before
`Toyloria Lanay Hunter, CSR in and for the State of
`Texas, reported by machine shorthand, at the law offices
`of ANDREWS KURTH LLP, 600 Travis, Suite 4200, Houston,
`Texas 77002, pursuant to the Federal Rules of Civil
`Procedure and the provisions stated on the record or
`attached hereto.
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 1 of 160
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`
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` A P P E A R A N C E S
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`Page 2
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`F O R T H E P E T I T I O N E R :
` N e d P e j i c
` J e n n i f e r B . W i c k
` C A L F E E , H A L T E R & G R I S W O L D L L P
` T h e C a l f e e b u i l d i n g
` 1 4 0 5 E a s t S i x t h S t r e e t
` C l e v e l a n d , O h i o 4 4 1 1 4 - 1 6 0 7
` T e l : 2 1 6 . 6 2 2 . 8 8 3 5
` E - m a i l : n p e j i c @ c a l f e e . c o m
` j w i c k @ c a l f e e . c o m
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`F O R T H E R E S P O N D E N T :
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` G r e g L . P o r t e r
` J a m e s W i l l s o n
` A N D R E W S K U R T H L L P
` 6 0 0 T r a v i s , S u i t e 4 2 0 0
` H o u s t o n , T e x a s 7 7 0 0 2
` T e l : 7 1 3 . 2 2 0 . 4 6 2 1
` F a x : 7 1 3 . 2 3 8 . 7 1 6 9
` E - m a i l : g r e g p o r t e r @ a k l l p . c o m
` j a m e s w i l s o n @ a n d r e w s k u r t h . c o m
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`- - a n d - -
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`F O R T H E R E S P O N D E N T :
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` J a m e s D . P e t r u z z i
` T H E P E T R U Z Z I L A W F I R M
` 4 9 0 0 W o o d w a y D r i v e , S u i t e 7 4 5
` H o u s t o n , T e x a s 7 7 0 5 6
` T e l : 7 1 3 . 8 4 0 . 9 9 9 3
` E - m a i l : j i m @ p e t r u z z i . c o m
`A L S O P R E S E N T :
` S t e p h e n L . S c h a r f , O w e n s C o r n i n g
` D a v i d C o l l i n s , F a s t F e l t C o r p o r a t i o n
` B . J . W a l t e r , F a s t F e l t C o r p o r a t i o n
` E d w a r d T o d d
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`www.veritext.com
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`888-391-3376
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 2 of 160
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`Page 3
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` I N D E X
` PAGE
`Appearances............................... 2
`Stipulations.............................. 1
`Signature and Changes..................... 129
`Reporter's Certification.................. 131
`
`DR. MARK BOHAN
`
` E X A M I N A T I O N
`
` By Mr. Pejic 4
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` E X H I B I T S
` Exhibit Description Page
`Ex. 2004 DECLARATION OF DR. MARK BOHAN 6
`Ex. 1003 U.S. PATENT NO. 6,451,409 13
`Ex. 1001 U.S. PATENT NO. 8,137,757 65
`Ex. 1002 '757 PATENT USPTO PRESENTATION 87
` HISTORY
`
`Ex. 1004 U.S. PATENT NO. 5,101,759 91
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`Ex. 1005 U.S. PATENT NO. 6,875,710 116
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`Ex. 1007 U.S. PATENT NO. 5,597,618 121
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 3 of 160
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`Page 4
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` DR. MARK BOHAN,
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`having been first duly sworn, testified as follows:
`
` EXAMINATION
`
`BY MR. PEJIC:
`
` Q. Good morning, Dr. Bowman. My name is Ned
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`Pejic. I am counsel for Owens Corning. How are you
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`today?
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` A. Very well, thank you.
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` Q. Could you please state your name and address
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`for the record?
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` A. My name is Dr. Mark Frederick John Bohan. And
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`my home address is 112 Amesbury Drive, Pittsburgh, PA
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`15241. And my work address is now 1000 Gutenberg Drive,
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`Kennesaw 30144, I believe. I would have to check that,
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`though. I've only just moved to that new work address.
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` Q. And that's in Pennsylvania, the work address
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`as well?
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` A. No.
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` Q. No? Just so I'm clear, your home address is
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`still Pittsburgh?
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` A. Correct.
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` Q. Okay. Are you a Steeler's fan?
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` A. (Laughing.)
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` Q. Okay. You're here to testify in connection
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`with a matter, IPR 201500650; is that correct?
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 4 of 160
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` A. That would be the correct number, yes, sir.
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` Q. Did you spend time preparing for this
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`Page 5
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`deposition?
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` A. Pardon?
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` Q. Did you spend time preparing for this
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`deposition?
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` A. I did spend time preparing.
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` Q. Can tell me how much time?
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` A. When you mean preparing for this deposition,
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`what are you referring to?
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` Q. What did you do to prepare for this
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`deposition?
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` A. I wrote my declaration and then continued
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`discussions afterwards.
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` Q. How much time did you spend writing your
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`declaration?
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` A. I don't know the breakdown of -- I spent about
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`120, 130 hours in total. I can't tell you the breakdown
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`without going back to it.
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` Q. That's fine. And how much time did you spend
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`preparing for the deposition today?
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` A. That's everything together.
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` Q. Oh, that's total?
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` Okay. Did you review any documents in
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`preparing your declaration?
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`www.veritext.com
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`888-391-3376
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 5 of 160
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` A. I believe all the documents are reviewed in
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`the third section of my declaration, which I don't have.
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`If you need me to go through them, I have my first
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`section of my declaration.
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` Q. Okay. Well, just so we're clear, I'm going to
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`hand you what's been designated as Exhibit 2004 in the
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`case. And it looks like it's your complete declaration.
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` (Exhibit 2004 identified.)
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`BY MR. PEJIC:
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` Q. So if you want to flip through it. But I'll
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`just keep referring to this document as your
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`declaration.
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` A. Thank you.
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` Q. So if you could take a look at it, and let me
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`know if that's. . .
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` A. (Reading.) On a quick review through, that
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`appears to be the correct one, yes.
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` Q. And is the section that you were referring to
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`earlier which describes the documents that you reviewed
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`in preparing that declaration, attached?
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` A. Yes, it is.
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` Q. And can you identify that section for me just
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`so we have it clear on the record?
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` A. That would be page 91, page 92, page 93, and
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`page 94.
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`www.veritext.com
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`Veritext Legal Solutions
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`888-391-3376
`
`Petitioner - Owens Corning
`Ex. 1021, Page 6 of 160
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`Page 7
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` Q. Is that what's called Appendix B or something
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`like that on there?
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` A. That would be Appendix B.
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` Q. Okay. So that is a complete list of the
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`documents you reviewed in preparing your declaration?
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` A. I believe I reviewed all the documents there.
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` Q. Okay. Did you do anything else in addition to
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`reviewing those documents in preparing your declaration?
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` A. I'm not quite sure I understand. This is the
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`first time I have done a declaration. So I'm just
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`unsure what you mean by that question.
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` Q. Okay. So one of the things you did is you
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`reviewed those documents?
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` A. Yes.
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` Q. Did you do anything else?
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` A. I reviewed those documents, and I used my
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`knowledge and the information. I thought those were the
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`documents I directly reviewed.
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` Q. You didn't have any discussion with anyone
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`else; is that what you're saying?
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` A. Well, I had discussions with Mr. Todd and the
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`lawyers here.
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` Q. Okay. What did you discuss with Mr. Todd?
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` A. We discussed roofing.
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` Q. What about roofing?
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 7 of 160
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` A. To gain an understanding and background to the
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`Page 8
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`roofing industry.
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` Q. And what --
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` A. And I believe I referenced that in my
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`declaration.
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` Q. And why did you need to gain an understanding
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`and background about the roofing industry?
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` A. Well, as you will see from my background, it's
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`in printing. I did not have an understanding of the
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`roofing industry to which this relates, and I needed to
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`understand that.
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` Q. Did you read anybody else's declaration in
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`preparing for this deposition?
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` A. I believe that I read Harvey Levenson's
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`declaration. And that's his reference, I believe, in
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`the Appendix B.
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` Q. Anyone else's declaration?
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` A. I read Mr. Todd's declaration.
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` Q. Anyone else's?
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` A. (Reading.) Clearly I read my own declaration.
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` Q. Did you discuss the matter with Mr. David
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`Collins?
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` A. What matter?
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` Q. This matter that you're testifying for today.
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` A. Mr. Collins was in the room with the lawyers
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`www.veritext.com
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`888-391-3376
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`Veritext Legal Solutions
`
`Petitioner - Owens Corning
`Ex. 1021, Page 8 of 160
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`Page 9
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`when we were having discussions.
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` Q. So did you have any discussions with
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`Mr. Collins?
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` A. He was involved in the discussion.
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` Q. Okay. And you spoke directly to Mr. Collins
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`during those discussions, correct?
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` A. During discussions, I spoke with everybody in
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`the room.
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` Q. Okay. How did you come to know Mr. Todd?
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` A. I came to know Mr. Todd through this process.
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` Q. And earlier you said your discussions with
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`Mr. Todd centered around gaining knowledge and
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`understanding regarding the roofing industry, correct?
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` A. That was -- we discussed the roofing industry,
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`yes.
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` Q. Do you know what Mr. Todd's credentials are
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`regarding the roofing industry?
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` A. I've reviewed his declaration, and I've seen
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`his curriculum vitae.
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` Q. Did you rely on your discussions with Mr. Todd
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`in forming the opinions contained in your declaration?
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` A. When I was writing my declaration, I used all
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`the references in my declaration that are listed in the
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`back.
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` Q. Okay. My question was, did you rely on your
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 9 of 160
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`discussions with Mr. Todd in forming your opinions that
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`are contained in this declaration?
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` A. The discussions with Mr. Todd provided
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`information, part of the information that I used to
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`write the declaration.
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` Q. And Mr. Todd's declaration also formed part of
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`the basis of your opinions in your declaration, correct?
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` A. My declaration was not based on Mr. Todd's
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`declaration; is that what you're trying to say?
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` Q. I was saying -- just let me ask the question
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`again.
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` Did you rely on Mr. Todd's declaration in
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`forming the opinions in your declaration?
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` A. So I'm -- I mean, I used the discussions, as
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`I've indicated, in my declaration. I used the
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`discussions, and I reviewed the declaration. And that
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`formed part of -- part of the basis of my declaration as
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`well.
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` Q. When you say --
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` A. Providing background information.
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` Q. Just so I'm clear, when you just said
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`"declaration," you were referring to Mr. Todd's
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`declaration?
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` A. I looked at Mr. Todd's declaration. And if I
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`read it, then it's going to -- as when I read any of the
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`www.veritext.com
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`888-391-3376
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 10 of 160
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`Page 11
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`other documents, they all formed part of the combined
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`knowledge.
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` Q. So your declaration that I handed to you, that
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`Exhibit 2004, do you believe your declaration to be
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`accurate?
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` A. I do believe, to the best of my knowledge,
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`that this declaration is accurate.
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` Q. Are there any changes, modifications, or
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`supplements you'd like to make to it?
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` A. What do you mean by -- I don't understand.
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` Q. Is there anything you'd like to change in your
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`declaration?
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` A. I don't believe -- when I'm looking through
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`it, I -- there are -- I have changed jobs. So at the
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`time of the declaration, I was doing one job. I'm doing
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`a different job now. So -- but at the time of this
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`declaration, I believe in the information.
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` Q. What portions of your declaration did you
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`write?
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` A. I wrote the substantive part of the
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`declaration.
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` Q. And what do you mean by "substantive part"?
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` A. I took guidance from the lawyers on items such
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`as the legal aspects.
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` Q. Anything else?
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 11 of 160
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`Page 12
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` A. I did not write this first page. I'm not sure
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`-- I used the -- the help with putting the legal aspects
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`in this and ensuring it was correct to the formatting
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`which is required for this.
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` Q. So the legal section, you got help with the
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`attorneys. Is that your position on where you got
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`assistance?
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` A. That was -- yeah, the main area I got the
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`assistance on.
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` Q. Did you exchange any drafts with the attorneys
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`of your declaration?
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` A. The drafts were exchanged.
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` Q. How many drafts?
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` A. I could not remember that number.
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` Q. Can you approximate the number?
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` A. Yes. Probably five. It could have been more.
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`It could have been less. I. . .
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` Q. So earlier when you said you had discussions
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`with Mr. Todd to gain an understanding of the roofing
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`industry, were there any topics that you specifically
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`focused on in those discussions?
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` A. We discussed several items. There was some
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`topics around heavily saturated asphalt manufacturer was
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`one of the areas.
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` Q. Any other areas that you recall?
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 12 of 160
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`Page 13
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` A. I mean, there were other areas. We discussed
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`the Lassiter pattern.
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` Q. What aspects did you discuss the Lassiter
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`pattern?
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` A. You know, helping with understanding a roofing
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`line.
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` Q. What do you mean by "roofing line"?
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` A. May I? These are clean. Am I allowed to look
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`at these, or do you want me to ask for the documents
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`from you?
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` Q. Well, let's start by identifying what you're
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`looking at.
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` A. I would like to look at the Lassiter patent;
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`am I allowed to do that?
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` Q. Absolutely. Did you have a copy or we can
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`provide you a copy.
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` A. I have a copy of the Lassiter I believe. Or
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`would you prefer to. . .
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` MS. WICK: I can get you one.
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`BY MR. PEJIC:
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` Q. So I'm going to hand you Exhibit 1003.
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` (Exhibit 1003 identified.)
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`BY MR. PEJIC:
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` Q. Is this the Lassiter patent that you're
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`referring to?
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`Petitioner - Owens Corning
`Ex. 1021, Page 13 of 160
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` A. (Reading.) I feel I need to check the number
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`'cause I do not remember numbers in my head. (Reading.)
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`That does appear to be the correct one.
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` Q. Okay. So I believe my question to you was,
`
`what do you mean by a roofing line?
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` And you said you'd like to refer to the
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`Lassiter patent; is that correct?
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` A. So I was referring to Figure -- an example in
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`this case, Figure 1.
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` Q. So you discussed Figure 1 with Mr. Todd; is
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`that correct?
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` A. That is one of -- I discussed Figure 1 amongst
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`other things with Mr. Todd.
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` Q. What other areas of discussion did you focus
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`on with Mr. Todd regarding gaining an understanding of a
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`-- of the roofing industry?
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` A. We covered many different areas. And not
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`exclusively, we discussed, for instance, roofing
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`installation.
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` Q. Any other areas?
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` A. We discussed asphalt saturated felt. Heavily
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`asphalt saturated felt.
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` Q. And what did you discuss about heavily
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`saturated asphalt felt?
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` A. We discussed several items. I can't remember
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`Petitioner - Owens Corning
`Ex. 1021, Page 14 of 160
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`every item. One of the items would be the manufacture
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`of it, the installation of it, the oils that come from
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`it.
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` Q. Anything else?
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` A. Many -- we discussed items -- I cannot
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`remember every second of every conversation that I've
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`had with Mr. Todd. And if I have a piece of paper, I
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`can start to write a very long list of items.
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` If we want to understand the manufacturing
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`amongst other items.
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` Q. So is it fair to say that the purpose of the
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`discussions with Mr. Todd was for you to gain an
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`understanding regarding the roofing industry?
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` A. That was one of the -- one of the areas that I
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`discussed with Mr. Todd was the roofing industry and the
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`components therein.
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` Q. Is it fair to say that's because you did not
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`have that understanding prior to your discussions with
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`Mr. Todd?
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` A. Prior to my discussions with Mr. Todd, I had a
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`very rudimentary understanding of the roofing industry.
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` Q. After you submitted your declaration in final
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`form, did you discuss it with anybody?
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` A. I discussed it with the people in this room
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`down on this side of the table (pointing.)
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`Petitioner - Owens Corning
`Ex. 1021, Page 15 of 160
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`Page 16
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` Q. I wasn't one of them; that's why I was
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`wondering. Can you please indicate which individuals?
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` A. Mr. Porter, Mr. Petruzzi, Mr. Collins,
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`Mr. Wilson, and Tom.
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` Q. And what was the purpose of discussing your
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`declaration after it was finalized with those
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`individuals?
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` A. I have never done a deposition previously. So
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`I needed to discuss the deposition and what a deposition
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`involved.
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` Q. And were you compensated for generating your
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`declaration?
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` A. I was compensated for my declaration.
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` Q. And who compensated you?
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` A. The compensation is coming from Andrews Kurth.
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`That payment is made to Printing Industries of America.
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`Personally, I see no -- so it goes to Printing
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`Industries of America.
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` And then as I have moved roles, a certain
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`portion of that now goes to Heidelberg to cover my time.
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`Would be spelled H-E-I-D-E-L-B-E-R-G.
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` Sorry about that. I realized there was a
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`spelling.
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` Q. Can you tell me who is Heidelberg?
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` A. Heidelberg USA are my new employers.
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 16 of 160
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`Page 17
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` Q. Are you an employee of Heidelberg?
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` A. Yes.
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` Q. What is your role?
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` A. I am a business consultant.
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` Q. Can you explain what that means?
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` A. Yes. In my role, I consult with companies
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`looking at performance and looking at productivity.
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`Improving profitability. I also write for them. In
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`addition, I represent Heidelberg USA for standards to do
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`with printing.
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` Q. What is Heidelberg's main business?
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` A. They are -- as I knew I would also like to
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`look at their official definition, so I can make a
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`comment. It's equipment and solutions for the printing
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`industry.
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` Q. When did you start working for Heidelberg?
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` A. November 30th, 2015.
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` Q. Can you tell me what type of solutions for the
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`printing industry are you referring to in the context of
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`Heidelberg?
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` A. So Heidelberg was a leading manufacturer of
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`offset printing presses. They sell digital printing
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`presses. They sell -- they've recently purchased a
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`company called Gallus and sell flexographic printing
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`processes -- presses.
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 17 of 160
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` They sell finishing equipment, which would
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`be cutters. They would also sell folders. There is
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`some binding, I believe; though it's in a transition at
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`the moment.
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` They sell white formatting jet. They also
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`provide prepress workflow systems. They would provide
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`digital asset management solutions. Management
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`information systems; which are used for managing
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`printing facilities. They sell lithographical offset.
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` THE WITNESS: Do you need me to spell
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`lithographic?
`
` THE REPORTER: No.
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` A. Printing plates. And they sell consumables,
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`which would be, ink, fountain solutions, spray powder,
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`plates, pretty well anything you need on a press.
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` And there is business consulting arm, of
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`which I sit within the business consulting.
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` They sell 3D -- or 4D, as they like to
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`call it -- printers, 'cause time is involved. I'm sure
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`about that. I probably missed some of the areas.
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` Without having a list and going through
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`it, it's difficult to remember everything on that one.
`
` Q. In what area do you consider yourself to be an
`
`expert?
`
` A. I would consider myself to be an expert in the
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`www.veritext.com
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`888-391-3376
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`Veritext Legal Solutions
`
`Petitioner - Owens Corning
`Ex. 1021, Page 18 of 160
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`Page 19
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`printing industry. Can I refer to my -- I mean, I
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`believe I referred to it in here. (Reading.)
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` Q. Are you referring to your declaration,
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`Exhibit 2004?
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` A. Yes. Sorry. I have to check my number there.
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`(Reading.) Yes. So I would say that that's a fair
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`assessment. I'm an expert in printing.
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` Q. Why do you believe you're qualified to be an
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`expert in printing?
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` A. I believe I'm qualified to be an expert in
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`printing due to the body of work that I have done, my
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`education, the research, the activities that I have
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`participated in.
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` If you would refer to Exhibit 204 [sic],
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`is it? Appendix A. That would be my curriculum vitae.
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`As you can see, at the time of writing this, I've
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`published over 102 publications. Many of those are peer
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`reviewed.
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` Over 200 invited lectures. Not always as
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`an expert in the printing field. And I've been asked to
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`keynote at various events. I write press articles.
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` In addition, in 2010 I was in the -- you
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`can tell my accent is English. I attained my green card
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`as an alien of extraordinary ability, based on my
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`printing background. So also that as being endorsed in
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 19 of 160
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`some manner by the US government when they provided that
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`green card under those criteria.
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` Q. Are you an expert in the manufacturing of
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`roofing materials?
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` A. I am not an expert on manufacture of roofing
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`materials.
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` Q. Are you an expert in the manufacture of
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`building materials?
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` A. What would you mean by "building materials"?
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` Q. Have you ever heard of that term before?
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` A. Building materials? Yes.
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` Q. What does that term mean to you?
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` A. Any material whatsoever. Any material
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`involved with a building.
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` Q. Are you an expert, under that definition, of
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`that subject matter?
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` A. I think that that is a very broad area. A
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`building material could be a wallpaper. For that, I
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`have expert knowledge of. For a manufacture of a brick,
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`I do not have that. They are both part of building
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`materials. So I don't see how I can answer that. Some
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`areas yes; some areas no.
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` Q. Are you an expert in building cover materials?
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` A. What -- how would you define "building cover
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`materials"?
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`www.veritext.com
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`Veritext Legal Solutions
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`888-391-3376
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`Petitioner - Owens Corning
`Ex. 1021, Page 20 of 160
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`Page 21
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` Q. What does the term mean to you?
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` A. Building cover materials? Within -- from what
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`I have learned on this and from my general knowledge,
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`would be considering roofing materials. However, there
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`may be other definitions.
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` A building cover could also be a wallpaper
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`in -- covering the inside of the building. So, again,
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`if you can try to be more specific.
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` Q. So if we just pause for a moment and look at
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`your last answer. You would consider yourself an expert
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`on a building cover material that is a wallpaper?
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` A. I would consider myself an expert on putting
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`an image onto a wallpaper. Not on putting a wallpaper
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`onto a building.
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` Q. What does the term "gravure" mean to you?
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` THE REPORTER: I didn't get that, I'm
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`sorry?
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` MR. PEJIC: Gravure, G-R-A-V-U-R-E. So
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`let me repeat the question.
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`BY MR. PEJIC:
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` Q. What does the term "gravure" mean to you?
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` A. Gravure, I would consider a printing process.
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` Q. What kind of printing process?
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` A. Do you wish me to describe the components
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`within a gravure? I mean, a printing process. Is that
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 21 of 160
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`Page 22
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`what you wish me to do? Would be the product.
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`Typically printing or the process?
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` Q. Well, if gravure means several things to you,
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`I'd like to understand all the things it does mean to
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`you.
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` A. Gravure is a -- is primarily looking at a
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`printing process for putting high-quality images onto a
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`substrate. An example might be the National Geographic
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`magazine.
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` Q. How does gravure work?
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` A. Gravure has -- how would you like me to -- how
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`detailed?
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` Q. You can begin wherever you'd like.
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` A. Gravure is imaged typically in a -- onto a
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`image carrier, would be gravure. From that, you would
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`have a gravure press. The substrate is typically a web.
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` It would then be fed through the press.
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`The image to be printed from the cell would rotate,
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`collect ink. That ink would be metered. It would be
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`transferred to the substrate under pressure with an
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`impression roll then be dried. And go onto a subsequent
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`printing unit.
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` Q. You referred to an image carrier. What is
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`that?
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` A. Image carrier would be a gravure cylinder.
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 22 of 160
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`Page 23
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` Q. What is a gravure cylinder?
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` A. Gravure cylinder is the image carrier. And it
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`creates the image that you want in the gravure process.
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`And, typically, it's etched or later engraved. Etched.
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`Well, typically now it's diamond engraved or laser
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`engraved.
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` Q. So what is etched or laser engraved, as you
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`say, on that cylinder?
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` A. The image to be transferred.
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` Q. How do things result in an image being
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`transferred?
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` A. As I said, it's typically engraved, not
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`etched. So it would be engraved. That would create a
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`recess in the surface of the cylinder. That would be
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`then filled with ink. From there, that would be metered
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`using a Dr. Blade.
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` And then brought into contact with the
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`substrate with a impression cylinder behind it, the ink
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`is transferred at that point.
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` Q. So earlier you mentioned another component of
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`a gravure is a gravure press. What is a gravure press?
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` A. A gravure press would be the complete system
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`to be able to take the material and handle it.
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` Q. Could you recite for me then what are the
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`components of the complete system known as a gravure
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 23 of 160
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`
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`press?
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` A. A gravure press will vary on configuration. A
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`-- may I have some paper and...?
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` MR. PORTER: (Complies.)
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` THE WITNESS: Thank you.
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` A. Sorry. It's under oath. So I want to try to
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`make this as accurate as possible. Again, this is a
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`first experience of doing this. A gravure press will
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`first of all have an unwind station. (Drawing.)
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` That unwind station may have a splicing
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`unit on it. From that unwind station, there will be
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`tension control to ensure that the web moves through the
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`press appropriately.
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` From that section, there will be often a
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`pretreatment to handle -- to look at, improve the
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`characteristics of the web for printing. So that would
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`be either a thing such as web cleaners or else
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`electrostatic to help the transfer from the cell, then
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`typically go into a single printing unit.
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` And it will be the image carrier gravure
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`cylinder that will be rotating in a bath of ink.
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`Different configurations, different presses, this is a
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`typical gravure press.
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` It will have an impression cylinder at the
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`rear of the web. So the web will pass through a net
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`Veritext Legal Solutions
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`Petitioner - Owens Corning
`Ex. 1021, Page 24 of 160
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`contact at that point. It's a rolling contact where the
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`surface speed of the gravure cylinder is going the same
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`-- similar speed to the surface speed of the web.
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` You don't want differentials because
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`you'll get image defects. We have the -- generally a
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`rubber-coated impression cylinder. It will pass through
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`that. It will then go through a drying unit to dry the
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`ink.
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` More web movement and temperature --
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`tension control throughout the web will run through
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`subsequent units. So in a printing press, you will
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`typically have multiple units because you're trying to
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`build an image up from multiple colors.
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` It will go through each of those units.
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`The units -- the units, the printing and drying is
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`repeated down. From that then it would go into an
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`unwind -- into a rewind, sorry.
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` Q. Why is the drying necessary?
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` A. The drying is necessary to prevent
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`contamination