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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`
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`2
`
`FOR THE PLAINTIFF(S):
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`1 A P P E A R A N C E S
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`
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`!
`
`3 Mr. Thomas N. Young
` YOUNG BASILE
`4 3001 West Big Beaver Road, Suite 624
` Troy, MI 48084-3107
`5 (248)249-3333
` young@youngbasile.com
`
` FOR THE DEFENDANT(S):
`
`6 7
`
`8 9
`
` Mr. Thomas R. DeVoe
` TAFT STETTINIUS & HOLLISTER LLP
`10 One Indiana Square, Suite 3500
` Indianapolis, IN
`46204
`11 317.713.3500
` tdevoe@taftlaw.com
`12
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`13
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`Do you have any plans to change your address in
`
`1
`
`Q
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`3
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`A
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`No.
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`2 the next six months?
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`"
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`Where are you currently employed?
`
`Okay.
`
`
`
`4
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`5
`
`Q
`
`A
`
`I'm self-employed in my own shop, A&T Auto
`
`6 Service and Tires.
`
`7
`
`8
`
`Q
`
`A
`
`Where is that located?
`
`8101 East Washington Street, Indianapolis,
`
`9 Indiana, 46219.
`
`10
`
`Q
`
`Okay. Was there a time when you became employed
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`11 by the company known as University Loft Company?
`
`12 And I say that because I know there's a more
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`13 formal name to the company as J Squared, but it
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`14 does business as University Loft.
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`Are you
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`15 familiar with both of those names?
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`16
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`17
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`A
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`Q
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`A
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`Yes, I am.
`
`Okay.
`
`And was there --
`
`Yes, I was employed there December 4th, '99,
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`18
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`19 1999.
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`20
`
`Q
`
`Okay. When did you terminate your employment
`
`21 there?
`
`22
`
`23
`
`A
`
`Q
`
`June 2nd, 2013.
`
`Okay.
`
`Would you mind repeating the first date?
`
`24 It was 1999?
`
`25
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`A
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`December 4th, 1999, if I remember correctly.
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`YVer1f
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`%
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`(((
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`-
`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`1
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`2
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`3
`
`Q
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`A
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`Q
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`Until?
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`June 2nd, 2013.
`
`Okay.
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`Continuously employed -- employed during
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`0
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`1
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`4 that time?
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`5
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`6
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`A
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`Q
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`Yes.
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`Okay. What -- what were your -- what did your
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`7 job entail?
`
`And you can use titles if -- if you
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`8 had any.
`
`9
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`10
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`11
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`A
`
`Q
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`A
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`You want progression of just what I did?
`
`Sure, yeah.
`
`Assistant plant manager is what I was hired as.
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`12 I was over all the production in the Indiana
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`13 facility, set up distribution, oversaw the whole
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`14 facility operation. And then I went to plant
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`15 manager, did pretty much the same thing; then
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`16 started entailing communication with overseas
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`17 production and product development.
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`18 And then I want to technical director,
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`19 which pretty much oversees operations, product
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`20 development, sourcing.
`
`21
`
`Q
`
`Okay. Well, that's an impressive resume. Why
`
`22 did you leave?
`
`23
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`24
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`25
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`A
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`Q
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`A
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`Disagreements with the owner.
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`What kind of disagreements?
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`Treatment.
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`YVer1f
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`%
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`.(
`*+,
`(((
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`)
`)
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`-
`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`1
`
`2
`
`A
`
`Q
`
`Yes.
`
`Okay.
`
`3 from the U.S.?
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`1
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`4
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`5
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`A
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`I believe it's made in the U.S.
`
`Everything under that you think comes
`
`Okay.
`
`All right. But the piece to the right,
`
`6 the actual rocker chair for the Vector chair --
`
`7
`
`8
`
`9
`
`A
`
`Q
`
`A
`
`The frame, the seat --
`
`That's all made in China?
`
`-- and the back --
`
`10 THE COURT REPORTER:
`
`Wait, wait.
`
`You guys
`
`11 are talking over each other.
`
`12 MR. DEVOE:
`
`And again, I want it for the
`
`13 record that I'm objecting to this whole line of
`
`14 questioning but --
`
`On relevance.
`
`15 MR. YOUNG:
`
`16
`
`Q
`
`Okay.
`
`Let's talk about China for a minute.
`
`17 Mr. Davis, do you recognize the name
`
`18 Justin Davis?
`
`19
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`20
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`21
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`22
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`23
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Yes.
`
`Did he -- was -- did he work for you?
`
`Yes.
`
`Or work with you?
`
`He worked with me or for me in my department
`
`24 for, I want to say, four to five years; but I
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`25 can't remember the exact time frame.
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`%
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`.(
`*+,
`(((
`%&
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`)
`)
`
`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`1 with this case. They're not part of your
`
`
`
`
`
`3
`
`Q
`
`Okay.
`
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`2 infringement claim.
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`
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`3
`
`!
`
`Are you're going to take your attorney's
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`4 advice on that? By the way, is Mr. DeVoe acting
`
`5 as your attorney today?
`
`6
`
`7
`
`A
`
`Q
`
`Yes, he is.
`
`Are you going to take his advice and not answer
`
`8 my question?
`
`9
`
`10
`
`A
`
`Q
`
`I'll follow his instructions.
`
`Okay. How did the -- if you know, how did the
`
`11 program to -- that ultimately resulted in the
`
`12 Wave chair -- how did it get started?
`
`13
`
`A
`
`If I recall correctly, James saw something like
`
`14 he always does and says, "Hey, can we do this?
`
`15 Can we make something like this?
`
`We need
`
`16 something to be able to complete with this one
`
`17 in the marketplace."
`
`18
`
`Q
`
`And when you say "James," you're talking about
`
`19 who?
`
`20
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`21
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`22
`
`23
`
`A
`
`Q
`
`A
`
`Q
`
`James Jannetides.
`
`The president of the company?
`
`Yes, sir.
`
`Okay. Mr. Davis said -- and if we need the
`
`24 exact words, I can get them for you -- but to
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`25 the effect that no development program goes
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`$'#
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`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`1 anywhere but what James drives it. Is that --
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`Okay.
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`!
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`And that's the case for the Wave chair?
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`Absolutely. This is one of his pet projects
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`5 that he wanted -- wanted something to build
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`6 market.
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`7
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`8
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`Q
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`A
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`Do you know why?
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`To my understanding, a couple reasons: The
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`9 military was being a huge number of them; the
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`10 college market, it was a good thing to offer for
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`11 the students.
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`First, they'll be able to
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`12 actually set on the floor, because the tablet
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`13 age is upon us.
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`14
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`15
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`Q
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`A
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`The tablet age? Yeah.
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`Less laptops, less -- it's anything but tablets
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`16 anymore.
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`17
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`18
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`19
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`A
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`Q
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`And this happened to be --
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`The gaming age too.
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`This chair is pretty convenient, as we can see
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`20 in the picture on Exhibit 39 for putting a book
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`21 for a tablet right on that base as it's acting
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`22 as a little --
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`23
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`A
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`Yes. You see less book anymore and more tablets
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`24 even in the college side.
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`25
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`Q
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`Okay.
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`Yeah.
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`So the short little disk with the
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`(((
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`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`1 floor rocker on the floor next to it is a
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`3
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`A
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`Yeah.
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`2 convenient way to use a tablet --
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`!
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`5
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`-- for college students?
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`4
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`5
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`6
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`Q
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`A
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`Q
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`Yeah.
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`Are you familiar with the fact that the program,
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`7 throughout a significant number of years, was
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`8 referred to as the "Trey" -- capital T-r-e-y --
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`9 "chair" program?
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`10
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`A
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`I think that was only in the beginning when we
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`11 were trying to figure out our own naming
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`12 process, not really so much as it was that
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`13 project, because we had looked at the Sauder
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`14 chair and saw it, give us a picture of it. Oh,
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`15 okay, that's a starting point. Now, how do we
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`16 do better?
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`17
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`18
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`Q
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`A
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`Q
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`The -- the Sauder chair was called the "Trey" --
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`Correct.
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`-- chair; isn't that correct?
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`19
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`20
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`21
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`A
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`Q
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`To my knowledge, yes.
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`Okay. So -- so you adopted that name for your
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`22 program to make a -- what?
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`Comparable chair or
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`23 competitive chair?
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`24
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`A
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`Comparable, competitive, hopefully with
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`25 improvements and make it a better chair, more
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`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`3 chair -- or as it was originally known, the
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`0
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`!
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`1 yeah.
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`2
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`Q
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`1
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`4 "Trey chair" -- not developed here in the
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`So if that was the case, why -- why was the Wave
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`5 United States?
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`6
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`A
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`It was. We did all the -- all the -- I would
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`7 say all the artwork, all the drafting, even
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`8 making -- taking models and trying to get the
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`9 shape correctly before we sent information
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`10 overseas.
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`11 Doing the injection molding and all that is
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`12 dramatically more expensive here than it is
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`13 there. And for the college market, there's a
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`14 price point you must hit.
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`15
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`Q
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`So the -- the injection molding activity and the
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`16 design work associated with it, that was what
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`17 was done in China?
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`18
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`A
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`That's correct.
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`19
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`22
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`Q
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`A
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`A
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`And everything else was done here?
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`We were doing everything else here.
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`In your team?
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`Yes. There should be photos showing where we
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`23 cut and changed, made rockers, our own rockers
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`24 working on the shape of the seat and back here.
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`25 The first chair that came in was actually
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`(((
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`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`1 made of wood. The frame was wooden so we could
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`And that was done here in the U.S.?
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`3
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`2 make adjustments to it.
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`7
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`4
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`Yes.
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`And who all was in that team besides yourself
`
`!
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`6
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`6 and Justin?
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`7
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`A
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`Robert Davis one of the other employees and then
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`8 some guys in the mill room; so we would go down
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`9 and tell them how we wanted stuff adjusted, and
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`10 they would go to work on it.
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`11
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`Q
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`Okay. So I've got you, Robert Davis,
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`12 Justin Davis, and the guys in the mill room?
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`13
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`14
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`16
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`A
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`A
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`Yeah.
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`Is that the whole team?
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`And James, whenever he was in.
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`Okay.
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`He'd come back, take a look at it. If he didn't
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`17
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`18 like something or he liked something, "How about
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`19 changing this?" "We can do this differently."
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`20 So ...
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`21
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`Q
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`So he was -- he was the final decision maker
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`22 with respect to going forward with any
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`23 particular design?
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`24
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`25
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`A
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`Q
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`Yes.
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`Did there come a time when the development
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`$'#
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`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`2 There might have been, but I don't recall at
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`Honestly I don't recall one being shipped over.
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`3 this point. It's been a while. I don't
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`1
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`4 remember us sending one over.
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`5
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`6
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`Q
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`A
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`Do you remember them asking for one?
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`Oh, yeah. They always wanted something to start
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`7 with. That's why this chair took so long is
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`8 back and forth, back and forth with drawings and
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`9 renderings trying to get them to understand how
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`10 it worked.
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`11
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`Q
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`Okay. Were there some designs along the way
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`12 that resulted from the back-and-forthing that
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`13 were rejected?
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`14
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`A
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`Absolutely. That's -- that's a normal process
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`15 with any product development.
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`Q
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`16
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`17
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`So the --
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`A
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`We send them what we want, and then they'll send
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`18 something they'd rather do that's easier for
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`19 them or they've seen or copied or something
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`20 else. And then we got to go back and go, "No,
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`21 you got to do this again." And then it's back
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`22 and forth again to or three times before you
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`23 finally get it pushed in their head this is how
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`24 it needs to be.
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`25
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`Q
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`All right.
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`(((
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`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`3 just, so Justin was my filter sometimes.
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`2 never got to read so -- I get 200 plus a day
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`No, sir. But there's a fair number of emails I
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`Well, when I say "written," I don't mean emails.
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`5 I mean a piece of paper, a letter, a written
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`6 opinion with his signature on it, actual
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`7 signature.
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`8
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`A
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`I don't recall one, but there might have been
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`9 something.
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`10
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`Q
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`I'll show you some documents in a while where
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`11 Mr. Davis said to China or to somebody in
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`12 China -- and I thought it was Sandra -- because
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`13 of a Sauder-owned design patent, we don't want
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`14 our chair to look like the Trey chair but we
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`Do
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`15 want to -- we want to simulate the function.
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`16 you recall taking that position or being guided
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`17 by that general principle?
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`18
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`A
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`That would -- I would say it was, again, trying
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`19 to make sure we make a better chair or make
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`20 improvements on it; but their -- their whole
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`21 philosophy in China is trying to copy anything
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`22 that exists exactly the way it is and making it
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`23 cheaper.
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`24 And when they see or know there's something
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`25 out there, they want to go do that exactly. So
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`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`Okay.
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`2 in 2010, I'd say it's about halfway through.
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`4 look at the product brochure that you still have
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`I don't honestly remember, sir; but it went out
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`But that's for sure, not -- if you take a
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`4
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`5 in front of you, that's for sure not what you
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`6 ended up having made?
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`7
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`8
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`9
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`A
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`Q
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`A
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`No.
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`What was wrong with it?
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`Well, it looks great; but it becomes problematic
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`10 for getting the strength in the back pieces,
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`11 having them strong enough, especially if you're
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`12 doing injection molding where they're not just
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`13 going to snap off the first time somebody leans
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`14 back or the fifth time.
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`15 In the college market, you've got to expect
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`16 it's going to take an enormous amount of abuse,
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`17 the same with military guys, but they're not
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`18 80-pound people. They range anywhere up to
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`19 300 pounds, and they've got to be able to take
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`20 some abuse. So you got to have it strong enough
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`21 it's going to handle the market it's going into.
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`22
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`23
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`Q
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`A
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`And that one wouldn't have made the cut?
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`I don't think so. I don't think the back, they
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`24 could have got it strong enough without using
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`25 some type of aluminum or something else, which
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`%
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`.(
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`(((
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`)
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`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`39.
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`3 copies that I brought with me for convenience.
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`4 Okay. Back with the question and answers.
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`These are not original exhibits. These are just
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`!
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`5
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`5 I'm going to show you a document that was part
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`6 of what was marked as Exhibit 13, Plaintiff's
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`7 Exhibit 13. It's also ULC0004376. Let's see.
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`8 It's from Sandra at Wanan to James, Gordon Tan,
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`9 Marcus Gibbs, and Justin Davis.
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`10 MR. YOUNG: Okay. Now, here's one that
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`11 didn't -- apparently doesn't have Adam's name on
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`12 it. Do I show it to him?
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`13 MR. DEVOE: Yeah, that's fine. I'll show
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`14 it to him.
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`15
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`16
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`17
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`Would you take a look at that?
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`(Witness complies.)
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`That's the only copy I have. So it refers to in
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`18 the middle to -- do you mind if I come over and
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`19 look at it with you for a second?
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`20
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`21
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`A
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`Q
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`No, you're fine.
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`Right here (indicating) it refers to a rotation
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`22 locking system equipped with a spring release
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`23 button with double locking pins similar to a
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`24 fishing reel thing. Does that ring any bells
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`25 with you? Do you remember anything about that?
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`*+,
`(((
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`)
`)
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`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`Not -- I've kind of got an idea what they're
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`2 talking about, but it's just -- it's not what he
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`1
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`3 actually mentioned, but I don't recall this one,
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`5
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`3
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`4 this version or this --
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`5
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`Q
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`Yeah. What is your idea of what they're talking
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`6 about?
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`7
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`A
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`Two pins drop in hook and catch, catch it.
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`8 That's what a fishing reel does.
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`9
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`10
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`11
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`Q
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`A
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`Q
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`This is for the purpose of latching the --
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`Latching the base would, be my assumption.
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`And let me finish that. It's for the purpose of
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`12 latching the floor rocker to the base plate?
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`13
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`14
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`15
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`16
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`A
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`Q
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`A
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`Q
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`Yes.
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`To put it in the desk chair configuration?
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`Yes.
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`Okay.
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`And those same latches would be operable
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`17 one way or the other to pull the pins out and
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`18 then you can decouple the floor rocker from the
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`19 base?
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`20
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`24
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`Q
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`A
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`Yes.
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`Okay. That apparently never flew?
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`Correct.
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`Why?
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`Well, I would say a couple reasons. One is,
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`25 right off the top of my head is, it would be
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`.(
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`(((
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`)
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`-
`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`4 That way you're apt to just rip them out if
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`3 two pins in the side of a piece of plastic.
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`1 harder to lock and unlock the chair and it being
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`4
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`2 strong enough to hold with just two pins, drop
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`5 somebody's leaning back. That's a pretty good
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`6 safety hazard.
`
`Q
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`Okay.
`
`7
`
`Do you know where that idea came from?
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`8 Did that come from China or did that come from
`
`9 you guys?
`
`10
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`A
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`I have no idea. I would say from them just by
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`11 the email.
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`12
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`Q
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`Okay. Yeah. Well, based on what you've been
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`13 telling me so far today, I get the impression
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`14 that there was cross feed going on. You were
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`15 telling them stuff. They were telling you
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`16 stuff. And --
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`17
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`A
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`That's normal back and forth.
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`You say, "Here's
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`18 how I want it."
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`19 They say, "How about you do it this way?"
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`20 "No, I want it this way."
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`21 "How about you do it this way?" And they
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`22 may come up with five different methods before
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`23 you finally either get them pushed to what you
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`24 want and start making the sample that way or you
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`25 go to a different vendor to try to get that
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`%
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`/+
`.(
`*+,
`(((
`%&
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`)
`)
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`-
`$'#
`-
`''
`#$$
`
`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

`
`1
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`A
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`3 putting the chair back together, would know
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`2 it's marked as "front" so people, when they are
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`So it can only go on one way. So that's why
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`5
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`4 which way to put it back together easier.
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`5
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`6
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`7
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`8
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`Q
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`A
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`Q
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`A
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`Easier or better?
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`Well --
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`Is it possible --
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`No, it's not possible where it latches or would
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`9 go together the other way. So that's why it's
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`10 marked "front," to make sure as you're putting
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`11 the chair back on to the base, it secures.
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`12
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`13
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`Q
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`A
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`Okay.
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`They could sit it on there, but it still would
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`14 not be secures. It would not hook.
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`15
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`16
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`Q
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`A
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`Q
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`If they sat on it, there's a danger issue?
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`Yes, sir.
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`It's going to come apart and kaboom?
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`17
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`18
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`19
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`A
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`Q
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`Fall over.
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`Yeah.
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`Gotcha. Now, was there a time when it
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`20 was somebody's idea to put the latches in the --
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`21 in the middle of the side edge rather than
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`22 offset toward the rear as is it shown in one of
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`23 the photographers?
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`24
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`A
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`Not that I recall, but it's always been the rear
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`25 from what we were looking at everything to make
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`YVer1f
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`%
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`/+
`.(
`*+,
`(((
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`)
`)
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`-
`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`4 the base attaches to the seat itself.
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`2 you put them the middle, you're reducing your
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`1 sure you get the leverage you need, because if
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`3 strength of the attachment of the chair and how
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`9
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`8
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`5
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`6
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`Q
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`A
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`Okay.
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`You put them farther forward, it gets easier to
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`7 pull them out or break them off when they're
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`8 leaning forward or doing something else with the
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`9 chair.
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`10 So the wider you get the latch in the front
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`11 and the latches in the back, the stronger it's
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`12 going to be, the latching points are.
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`13
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`Q
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`Okay. So on the Wave chair, you've got the hook
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`14 from the chair onto the base in the front --
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`15
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`16
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`17
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`18
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`A
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`Q
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`A
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`Q
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`Um-hum.
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`-- and the two latches toward the rear?
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`Yes.
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`And that's the best arrangement for strength,
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`19 stability, safety?
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`20
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`21
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`22
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`23
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`24
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`25
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`A
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`Q
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`A
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`Q
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`A
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`Q
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`Yes.
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`You agree?
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`Yes.
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`Okay. Whose idea was that?
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`Honestly, I don't know.
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`We've been through --
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`YVer1f
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`%
`+
`/+
`.(
`*+,
`(((
`%&
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`)
`)
`
`-
`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`

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`
`We've been through the business with the fishing
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`It could have been a collaboration or it could
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`1
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`A
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`3
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`Q
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`2 have been --
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`8
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`2
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`4 reel, the pins, and so forth and that didn't
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`5 fly.
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`6
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`A
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`There was probably half a dozen through there,
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`7 that came through over time that isn't mentioned
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`8 in stuff.
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`9
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`Q
`
`Okay.
`
`So finally we get down to what we know
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`10 the product is. And that's the hook in the
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`11 front and the -- and the spring biased latches
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`12 towards the rear.
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`13
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`14
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`A
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`Q
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`The rear, yes.
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`And that one seems to be -- well, it's what you
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`15 adopted. But the question is: How did that --
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`16 whose idea was that?
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`A
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`17
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`I honestly don't know. Just probably sitting
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`18 around figuring out ways of latching and for how
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`19 the chair would latch to the base. And there
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`20 was more than one session that I know of.
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`21 I remember us sitting there fussing around
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`22 how to make it and make it also user friendly
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`23 and it has to be effective in holding the two
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`24 pieces together and handle all the abuse it's
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`25 going to get; so ...
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`YVer1f
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`%
`+
`/+
`.(
`*+,
`(((
`%&
`
`)
`)
`
`-
`$'#
`-
`''
`#$$
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`REDACTED Sauder Exhibit 2043
`JSquared Inc. v Sauder Manufacturing Co.
`IPR2015-00774
`
`