Declaration of Dr. Mark Bohan
`IPR2015-00650
`
`UNITED STATES PATENT & TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`OWENS CORNING,
`Petitioner
`
`FAST FELT CORPORATION,
`Patent Owner
`
`Case IPR2015-00650
`U.S. Patent No. 8,137,757
`
`DECLARATION OF DR. MARK BOHAN REGARDING
`U.S. PATENT 8,137,757
`
`MAIL STOP "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-145
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`Page 1 of 48
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`I, Dr. Mark Bohan, do hereby declare and state, that all statements made herein of my
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`own knowledge are true and that all statements made on information and belief are believed to
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`be true; and further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both, under Section
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`1001 of Titie 18 of the United States Code.
`
`Dated: November 20, 2015
`
`Dr. Mark Bohan
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`FAST FELT 2004, pg. 2
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`TABLE OF CONTENTS
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`I.
`
`INTRODUCTION .............................................................................................. 5
`A. Engagement ................................................................................................... 5
`B. Background and Qualifications ..................................................................... 5
`C. Compensation and Prior Testimony .............................................................. 7
`D.
`Information Considered ................................................................................ 7
`II. PATENTABILITY ........................................................................................... 10
`A. My Understanding of the Legal Standards for Patentability, Obviousness 10
`B. The Person of Ordinary Skill in the Art ...................................................... 12
`III. Discussion Of The Background Technology ................................................... 16
`A. Paper Is Not A Roofing or Building Cover Material .................................. 17
`B. A Non-Contact Process Is Completely Distinct From A Contact Process .23
`C. Traditional Gravure Methods Cannot Print a Nail Tab .............................. 24
`D. Lassiter Is Not A Print ................................................................................ 28
`E. Claims 1 and 7 are Not Printing Process .................................................... 29
`F. Cell Depth And/Or Starting Film Thickness Do Not Equate To Printed
`Or Coated Film Thickness .......................................................................... 31
`IV. Discussion of the Prior Art ............................................................................... 31
`A. Lassiter ........................................................................................................ 31
`B. Hefele .......................................................................................................... 34
`1. The Hefele Device Will Not Function With A Heavily Asphalt
`Saturated Substrate ................................................................................... 34
`2. The Hefele device cannot produce a nail tab ........................................... 36
`3. Hefele Does Not Teach The Use Of Bonding Or Adhering Pressure ...... 38
`C. Eaton ............................................................................................................ 39
`1. Eaton Expressly Teaches Away From Substrates Such As Asphalt
`Saturated Roofing Or Building Cover Materials ...................................... 39
`2. Eaton Would Not Work If Used With Asphalt Saturated Roofing Cover
`Material ..................................................................................................... 40
`D. Bayer ........................................................................................................... 42
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`o
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`The Bayer Devices Cannot Produce A Nail Tab When Substituted
`in Lassiter Line 18 .................................................................................... 42
`The Bayer Device Is Not Compatible With Heavily Asphalt Saturated
`Substrates Like Roofing Or Building Cover Materials ............................ 44
`DR. LEVENSON’S DECLARATION ............................................................ 46
`CONCLUSION ................................................................................................ 47
`
`go
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`I.
`
`INTRODUCTION
`
`A. Engagement
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`1. I have been retained by counsel for Patent Owner Fast Felt Corporation
`
`("Fast Felt") as an expert witness in the above-captioned proceedings. I have
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`been asked to render an opinion regarding the validity of claims 1, 2, 4, 6, and 7
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`of U.S. Patent No. 8,137,757 (the "’757 Patent") (Ex. 1001). I will refer to this
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`patent as the "Patent-In-Issue."
`
`B. Background and Qualifications
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`2. I, Dr. Mark Bohan am a professional with in-depth business and technical
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`knowledge of the graphic communications industry with a recognized adeptness
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`to navigate a broad range of topics. A proven ability to develop new programs,
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`assess technologies from a business and a technical perspective and to grow
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`revenue. I possess acknowledged expertize on the application of new and
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`innovative solutions, along with the optimization of production through
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`workflow and automation solutions.
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`3. I have earned a Bachelor of Science Honors degree in Mechanical
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`Engineering and a PhD focused on the sizing of irregularly shaped particles by
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`laser based techniques.
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`4. I am a member of the executive team at Printing Industries of America,
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`steering the company focus while managing a diverse group of business and
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`technology services. I have been a key decision maker and player in many
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`changes that have occurred in the organization. I have a comprehensive network
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`of industry printer and supplier contacts as a result of detailed evaluations of
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`technologies and company procedures. I preceded this with an R&D career
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`where my PhD focused on laser anemometry and particle sizing, followed by
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`twelve years of postdoctoral university research investigating printing processes
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`from a manufacturing perspective. My research results have been used in
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`printing equipment design.
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`5. My activities have generated 103 publications, 235 invited lectures, 81
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`press articles and successful collaborations with over 500 companies. In July
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`2010, I was recognized by the US government as an alien of extraordinary
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`ability in my successful Green Card application for my research and activities
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`in graphic communications. To qualify in this category it must be established
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`that the applicant has reached a level of expertise indicating that they are one of
`
`that small percentage who has risen to the very top of their field of endeavor.
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`6. I have extensive knowledge with respect to rotogravure printing. I formed
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`and managed a large research group in rotogravure with over 50 companies,
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`developed and taught at undergraduate and postgraduate programs, helped
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`supervise PhD students, served as a judge for the European Rotogravure
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`Association, spoken at conferences worldwide and published in peer reviewed
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`Declaration of Dr. Mark Bohan
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`journals.
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`7. My complete CV is attached to this declaration as Appendix A.
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`C. Compensation and Prior Testimony
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`8. I am being compensated at a rate of $225 per hour for my work in
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`connection with this matter, such as my study and review of the Patent-In-Issue,
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`related prior art and other materials. I am also being reimbursed for reasonable
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`and customary expenses associated with my work in this proceeding. My
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`compensation is not contingent on the outcome of this proceeding or the
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`specifics of my testimony.
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`D. Information Considered
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`9. My opinions are based on my approximately 25 years of education,
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`research, and experience in the field of printing and coating technologies as well
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`as my investigation and study of the relevant materials. In forming my
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`opinions, I have considered the materials referred to herein and listed in
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`Appendix B.
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`10. I have had extensive research experience in offset, gravure and
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`flexographic printing evaluating the interaction between the different system
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`configuration and consumables on the quality of the final output characteristics.
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`This included extensive use of real world printing presses and was not limited
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`to laboratory investigations.
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`11. The research I carried out was some of the first using experimental
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`design in a printing environment.
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`12. The temperature control of printing is critical in ensuring printing
`
`remains consistent. The research in offset printing showed that a 10 degree C
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`change in the ink temperature could cause up to a 0.4 density difference, this
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`would equate to approximately a 30% change. Typical results are shown in the
`
`figure 1 below. [Ex. 2006 - Bohan, M.F.J., Claypole, T.C. and Gethin, D.T.
`
`"An investigation into the effect of process parameters on the ink supply
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`characteristics to a roller train in a offset printing press", J. Prepress & Printing
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`Technology, vol. 3, March 1999.] The complexity of the response is further
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`complicated in this case by the opening of the fountain roller. These results
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`show the highly sensitive and complex relationships that must be controlled in
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`order to obtain a high quality print.
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`05--
`
`=03
`
`÷
`*,+
`
`&
`o o
`
`40
`
`Figure 1 - Ex. 2006, p. 5. Relationship between scanned coverage and ink
`
`density for a l0° C temperature change
`
`13. There are many factors in gravure printing that will impact the transfer of
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`ink to the substrate. This includes, but is not limited to, the geometry of the
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`cell, the rheological properties of the fluid being transferred, the transfer
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`temperature, the characteristics of the pressures in the printing system and the
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`surface characteristics of the gravure cylinder.
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`14. I may rely upon these materials and/or additional materials to rebut
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`arguments raised by the Petitioner. Further, I may also consider additional
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`documents and information in forming any necessary opinions, including
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`documents that I may not yet have reviewed and documents that have not yet
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`been provided to me.
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`15. My analysis of the materials relating to this proceeding is ongoing, and I
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`will continue to review any new material as it is provided. This declaration
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`represents only those opinions I have formed to date. I reserve the right to
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`revise, supplement, and/or amend my opinions based on any new information
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`and on my continuing analysis of the materials referred to herein and listed in
`
`Appendix A.
`
`II.
`
`PATENTABILITY
`
`A. My Understanding of the Legal Standards for Patentability,
`Obviousness
`
`16. In expressing my opinions and considering the subject matter of the
`
`claims of the Patent-In-Issue, I am relying upon certain basic legal principles
`
`that counsel have explained to
`
`17. I have been informed and understand that claims are construed from the
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`perspective of a person of ordinary skill in the art at the time of the claimed
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`invention, and that, during inter partes review, claims are to be given their
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`broadest reasonable construction consistent with the specification.
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`18. I have also been informed and understand that the subject matter of a
`
`patent claim is obvious if the differences between the subject matter of the
`
`claim and the prior art are such that the subject matter as a whole would have
`
`been obvious at the time the invention was made to a person of ordinary skill in
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`the art to which the subject matter pertains. I have also been informed that the
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`framework for determining obviousness involves considering the following
`
`factors: (i) the scope and content of the prior art; (ii) the differences between the
`
`prior art and the claimed subject matter; (iii) the level of ordinary skill in the art;
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`and (iv) any objective indicia of non-obviousness. I understand that the claimed
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`subject matter would have been obvious to a person of ordinary skill in the art
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`if, for example, it resulted from the combination of known elements according
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`to known methods to yield predictable results, the simple substitution of one
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`known element for another to obtain predictable results, use of a known
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`technique to improve similar devices in the same way or applying a known
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`technique to a known device ready for improvement to yield predictable results.
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`I have also been informed that the analysis of obviousness may include recourse
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`to logic, judgment, and common sense available to the person of ordinary skill
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`in the art that does not necessarily require explication in any reference. I also
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`understand that routine experimentation in order to optimize a result-effective
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`variable would also be obvious to a person of ordinary skill.
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`19. In addition, I understand that the obviousness inquiry should not be
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`performed with the benefit of hindsight, but should be considered through the
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`eyes of a person of ordinary skill in the relevant art at the time of the claimed
`
`invention.
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`Declaration of Dr. Mark Bohan
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`B. The Person of Ordinary Skill in the Art
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`20. Based on my review of the ’757 Patent, my mechanical engineering
`
`degree, my Ph.D., and my 25 years of work experience in the field of printing
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`and graphic arts, I believe the field of invention for the ’757 Patent is the
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`manufacture of roofing and building cover materials with reinforcing polymer
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`nail tabs. The preamble for both independent claims in the ’757 Patent claims a
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`"method of making a roofing or building cover material." [Ex. 1001, Collins
`
`757, Claims 1 and 7].
`
`Specifically, to make these roofing and building cover
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`materials, a substrate
`
`is heavily coated with a waterproof or weatherproof
`
`coating, an asphalt coating. [Ex. 1001 Col. 7:50-54].
`
`Polymer nail tabs are
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`pressed into this asphalt coating, by pressure from a roll,
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`during the roofing and
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`building cover materials’ manufacturing process.
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`21. I do not believe that the field of printing and graphics arts is the correct
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`field of art in which to understand the Collins ’757 patent.
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`22. It is my opinion that the person of ordinary skill in this art has a
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`bachelor’s degree, and potentially some advanced schooling, in chemistry,
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`engineering (such as chemical, civil, or mechanical engineering), materials
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`science, physical science, or a related discipline, and a minimum of 3-5 years of
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`additional training and experience in the field of manufacturing asphalt roofing
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`and building cover materials.
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`Declaration of Dr. Mark Bohan
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`23. Based on my discussions with Mr. Ed Todd, an expert in the manufacture
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`of roofing and building cover materials, my understanding is that making
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`discontinuous roofing and building cover materials from extended lengths of
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`substrate materials is a decades old process. Industry participants employ
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`substantially the same equipment and processes and produce similar very
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`products. An ordinary artisan in the field of manufacturing roofing or building
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`cover materials would be very familiar with these processes and the related
`
`equipment.
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`24. The physical features of a heavily asphalt coated or saturated substrate
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`should be understood by one skilled in the art. The hot, soft and tacky nature of
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`asphalt saturated substrate presents a variety of challenges unique to heavily
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`coated or saturated products and entirely unrelated to traditional paper products.
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`One skilled in the art would readily understand the difference between asphalt
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`coated or saturated felt and unsaturated dry felt. One skilled in the art would
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`also readily understand the difference between a heavily asphalt coated
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`substrate and "paper."
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`25. One such difference is the thicknesses and volumes of materials
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`employed in making roofing and building cover materials. In the field of
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`manufacturing roofing cover materials, the substrates are typically carriers of a
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`heavy asphalt coating. The asphalt serves as a waterproof or weatherproof
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`IPR2015-00650
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`coating and is coated on both sides of the substrate carrier or is saturated
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`through the substrate. The asphalt material is 100% to 150% of the weight of
`
`the substrate carrier in the finished product. The substrate carries the asphalt to
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`the roof deck and, along with a fastening system, holds the asphalt water /
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`weather proofing to the roof deck to cover and protect the building. The
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`thickness and volumes of materials used, and the processes which deposit or
`
`apply them, uniquely define this field of industry and would be understood by
`
`one skilled in its art.
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`26. Despite not having a significant amount of experience directly related to
`
`roofing, I know that the purpose of a roof is to help defend a building or
`
`structure from adverse weather. This requires the roof and the components
`
`comprising the roof to be securely fastened to the structure of the building and
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`also to be relatively waterproof. These requirements are supported by my
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`simple common sense, the research I performed related to this case and my
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`discussions with roofing expert Ed Todd. A person of ordinary skill in the field
`
`of roofing would clearly understand the need for roofing or building cover
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`materials to be water / weather proof.
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`27. I believe that it is important to note that the Petitioner, Owens Coruing,
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`has employed an expert in eight other IPR Petitions against a single roofing
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`industry participant. This Petitioner’s expert opined on nail reinforcement of
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`roofing materials and used similar wording, to describe a person skilled in the
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`art, as I have used above.
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`28. I believe that I am reasonably an expert in printing and graphic arts.
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`29. I believe that printing and graphic arts is not the correct field of art
`
`related to the Collins ’757 Patent.
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`30. As a person skilled in the art of printing and graphic arts, I do not believe
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`that a person solely skilled in the art of printing and graphics could understand
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`the processing problems in the asphalt roofing products industry or the inherent
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`issues addressed in the ’757 Patent. A person skilled solely in the art of printing
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`would not understand the processing issues inherent to applying polymer to
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`roofing cover materials in order to produce nail tab. This person would also not
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`understand the very complex problems associated with employing print
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`processes designed to transfer microscopic particles or extremely thin layers of
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`material onto heavily saturated roofing cover materials and expect to form nail
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`tabs with predictable results.
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`31. Despite my belief that someone solely skilled in the art of printing or
`
`graphics art would not be qualified to understand critical elements of the ’757
`
`patent, the below analysis of the prior art references uses the perspective of an
`
`ordinary artisan in the field of printing and graphic arts. More specifically the
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`below analysis uses the perspective of someone with a bachelor’s degree with
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`knowledge of various printing methods and several years of industry experience
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`in the printing field as described by Petitioner’s expert. [Ex. 1014, ¶13]. In
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`considering the patentability of the ’757 Patent claims 1, 2, 4, 6 and 7, and
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`describing my opinions below, I have used the perspective of a person of
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`ordinary skill in the art of printing and graphic arts at the time of the earliest
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`possible filing date of the subject matter at issue, i.e., May 29, 2003, which I
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`understand to be the filing date of the earliest provisional patent application in
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`the family of patent applications that resulted in the Patent-In-Issue.
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`III. Discussion Of The Background Technology
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`32.
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`I do not believe that any process which consistently transfers an image
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`onto a heavily asphalt coated surface has been successfully employed
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`commercially and Petitioner’s expert could not cite such a reference at his
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`deposition. [Ex. 2005, Levenson depo, pp. 8-9] In my review of the prior art in
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`this matter, Lassiter, Hefele, Bayer and Eaton, the following is readily apparent
`
`to me:
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`¯ Asphalt Saturated Felt is not properly considered a "paper";
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`¯ None of the secondary references could deposit a nail tab onto an
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`asphalt saturated felt or other roofing cover material; and
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`¯ The Lassiter patent discloses a non-contact method and there is no
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`reason at all to combine it with a contact method since it teaches
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`away.
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`A. Paper Is Not A Roofing or Building Cover Material
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`33. The Petition of this IPR, supported by the declaration of Dr. Harvey
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`Levenson, asserts that "paper" is a roofing product. This assertion is supported
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`by the following phrase, "Paper is a form of recognized roofing or building
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`cover material." [Ex. 1014, Levenson Dec. ¶32]. To support this phrase, Dr.
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`Levenson cites the Lassiter ’409 patent 1:25-28 & 3:24-25 claiming the Lassiter
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`Patent specifically notes "paper" as a roofing or building cover material. This
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`assertion is repeated throughout the Petition and Levenson declaration at least
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`five times and used to justify the combination of Lassiter and every other prior
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`art reference currently at issue. [Levenson Dec. Ex-1014 ¶¶32, 53, 64, 82 and
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`103]. The Lassiter ’409 patent does not suggest paper is a roofing cover
`
`material in any way.
`
`The cited portion of the Lassiter ’409 Patent states:
`
`"A shingle roof
`
`installation generally comprises at least two
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`distinctive layers.
`
`The first layer is an underlayment, usually a
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`saturated asphalt material that attaches directly to the plywood sheets
`
`or board material that supports the shingles. The second layer is made
`
`up of the shingles themselves. Normally, the underlayment assists in
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`making the roof resistant to water intrusion. The starting material for
`
`the underlayment is a base material usually referred to as "dry felt".
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`Examples of types of dry felt starting material are rag, paper and
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`fiberglass, which is not exhaustive of possible starting base
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`materials." [Ex. 1003, Col. 1:18-28].
`
`"Dry felt material when saturated with an asphalt material produces an
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`underlayment roofing material known in the trade as "tar paper" or
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`"saturated felt", which is produced in various grades depending on
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`thickness and weight." [Ex. 1003 Col. 1:34-38].
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`"A composite roofing material is made starting with a roll of dry felt
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`material. In the preferred method of producing the underlayment
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`roofing material in accordance with this invention, the dry felt
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`material is introduced to the beginning of a continuous and automated
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`process having a system of driven rollers for transporting the roofing
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`material through the process. First, the dry felt material undergoes
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`treatment in conventional fashion to produce asphalt saturated felt
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`material from the dry felt." [Ex. 1003, Col. 3:24-32].
`
`34. This language is echoed in the Collins ’757 Patent as well. [Ex. 1001,
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`’757 Patent, Col. 1:35-Col. 2:11]
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`35. The Lassiter ’409 patent makes it very clear that "paper," along with rag
`
`and fiberglass are potential starting materials for dry felt. He makes it equally
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`clear that dry felt only becomes a roofing underlayment after it has been
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`saturated with an asphalt material. The assertion that "[p]aper is a recognized
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`form of roofing or building cover material" is entirely divorced from both the
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`teachings of Lassiter and the common understanding of what is referred to as
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`"paper" in the printing industry.
`
`36. Lassiter and Collins teach that roofing materials are water / weather
`
`proof. [Ex. 1001, ’757 Patent, Col. 1:49-51; Ex. 1003, Lassiter ’409, Col. 1:22-
`
`24]. One need not be an expert in printing to be well aware that "paper" is not
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`waterproof. As the Lassiter patent makes clear, paper (along with rags and
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`fiberglass) may be a starting material for dry felt. Dry felt may then be
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`saturated with asphalt. Once the dry felt has been saturated with a heavy
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`coating of asphalt, it is then weatherproof and may be used to make shingles, or
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`other roofing products.
`
`37. In the printing industry, "papers" are generally considered to be made of
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`a cellulose substrate (paper fiber for example) that may or may not be coated.
`
`Papers are generally not considered to be water / weather proof, a key
`
`component of a roofing cover material. Traditional paper coatings include clay
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`and/or other materials aimed at modifying the optical appearance or printability
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`of the paper. The printability changes are often designed to optimize the ink
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`absorbance and ink adhesion to the paper. These coatings form a relatively
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`small percentage of the paper thickness. No traditional paper coatings cause
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`paper to become water resistant. Paper could be made water resistant via a
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`secondary coating or post production finishing process.
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`Following this
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`processing, the product would not be referred to as "paper".
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`38. The field of printing and graphic arts does not address substrates with
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`physical properties similar to asphalt saturated felt. By saturating a paper
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`product with asphalt, the physical properties of the product change dramatically.
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`The surface of saturated felt is highly deformable when compared to paper. The
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`nature of the physical properties of saturated felt is highly temperature
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`dependent, whereas the physical properties of paper are relatively stable across
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`a very wide range of temperatures. While paper may be one of the many
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`starting materials for a heavily asphalt saturated roofing material, the factors
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`impacting the printability of such a substrate are very different from paper.
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`39. The temperature dependent nature of an asphalt saturated substrate’s
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`physical properties greatly complicate the printing and coating process. Even if
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`the sheet of saturated felt were kept cool, the heat associated with depositing a
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`hot liquid thermoplastic would drastically impact the physical properties of
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`saturated felt in the immediate area undergoing polymer deposition. Even if
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`one were to ignore this significant shift in physical properties, at no point would
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`asphalt saturated felt be reasonably considered a paper.
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`FAST FELT 2004, pg. 20
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`40. The Collins patent independent Claim 1 contemplates depositing nail tabs
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`as part of a production line which includes treating a substrate using an asphalt
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`saturation process. [Ex.1001, Col. 7:50-54; Claim 1]. I understand the
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`saturation process to involve heavily saturating dry felt or fiberglass mat with
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`approximately 450 degree F asphalt either by submerging the dry felt into a
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`saturation tank, or by heavily spray coating the dry felt with hot liquid asphalt.
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`Due to the high temperatures involved in the saturation process, it seems any
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`application of nail tabs to saturated felt that is coupled with the saturation
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`process would be completely divorced from the traditional understanding of
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`printing on paper. Treating asphalt saturated felt as if it were a traditional paper
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`is an unreasonable substitution and will not lead to expected results.
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`41. In the printing industry, the contamination of the ink and printing system
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`by materials from the paper is a major concern. This contamination will affect
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`with the transfer of a consistent quantity of ink onto the substrate. The
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`objective, in printing, is to eliminate contaminations wherever possible and
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`minimize their impact. These contaminants can cause a complete failure of the
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`printing system causing the press production line to be stopped.
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`42. All printing processes are a balance of all of the components in the
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`system and changes in any of the components can result in a significant change
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`in the transfer characteristics. Much of my research has been in this area and has
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`shown the sensitivity to transfer from changes to different press and
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`consumable states. Figure 2 shows the complexity of the rotogravure printing
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`process and the factors that need to be considered for the effective transfer. [Ex.
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`2009, pg. 3 of 16].
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`THE EFFECT OF PROCESS PARAMETERS ON PRODUCT QUALITY OF ROTOGRAVURE PRINTING
`
`207
`
`INK
`
`Viscosity
`¯ Solvent, recireulation, colour
`Elastleity
`Surface tension
`Overprinting
`CaNer properties
`Colourimetric properties
`¯ Pigment, opacity
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`PRE-PRESS
`Scanning & scanner
`Origination
`RIPs
`Transfer algorithms
`Gamut compression
`Colours used
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`SUBSTRATE
`Surface treatment
`Substratc type
`Surface finish properties
`¯ Porosity, chemistry, surface energy
`Opacity
`Colour
`Thickness
`Tension
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`CYLINDER
`Engraving type
`Cell geometry
`Cylinder type
`Cylinder geometry
`Chemistry properties
`Image composition
`Coating
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`Fig. 2 Factors aff~ting print qualib in rotogravure printing
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`PROCESS
`Doctor blade
`¯ type
`¯ load
`¯ angle
`Colour sequence
`Print speed
`Impression roll
`¯ pressure
`¯ rubber properties
`. geometry
`Environmental
`conditions
`¯ temperature
`¯ humidity
`¯ solvents
`Web properties
`Web manipulation
`Machine
`¯ design
`¯ aCCU~Cy
`Curing
`¯ type
`¯ total
`¯ cross unit
`Cooling systems
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`43. I have been informed by roofing expert Ed Todd that there is a very
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`noticeable transfer of the oils from asphalt saturated felt at a temperature 98
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`degrees F. As the temperature of the asphalt saturated felt increases so does the
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`amount of oil released from it. This release of oils would be a significant
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`concern with any contact print mechanism and would teach away from the use
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`Page 22 of 48
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`FAST FELT 2004, pg. 22
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`Declaration of Dr. Mark Bohan
`IPR2015-00650
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`of a contact print solution. This contamination could provide
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`catastrophic
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`failure of the printing process in many situations.
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`B.
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`A Non-Contact Process Is Completely Distinct From A Contact
`Process
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`44. There
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`is a significant difference between a non-contact and contact
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`process from both a physical and chemical perspective. In many cases it would
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`not be obvious or advisable to move from a non-contact to a contact process.
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`45. In moving to a contact process there will be a large, or very large,
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`increase in the pressure applied to