throbber
Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 1 of 15 PageID #: 84
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`DNA GENOTEK INC.,
`
`v.
`
`Plaintiff,
`
`C.A. No. 15-cv-00661-SLR
`
`SPECTRUM DNA; SPECTRUM SOLUTIONS
`L.L.C.; and SPECTRUM PACKAGING L.L.C.,
`
`Defendants.
`
`DECLARATION OF JUAN C. LASHERAS, PH.D.
`
`I, Juan C. Lasheras, hereby declare as follows:
`
`Education and Professional Background
`
`1.
`
`I am the Founding Director of the Center for Medical Devices and
`
`Instrumentation at the University of California, San Diego (“UCSD”). I am also the Stanford
`
`and Beverly Penner Professor of Engineering and Applied Sciences in the Department of
`
`Mechanical and Aerospace Engineering and Bioengineering at UCSD, and a Member of the
`
`National Academy of Engineering of the USA.
`
`2.
`
`Prior to joining the faculty at UCSD, I held several research and teaching
`
`positions in Europe and the USA, including serving as the Dean of the Jacobs School of
`
`Engineering at UCSD. I have lectured extensively in the United States, Spain, and France. I
`
`also served as a 2nd Lieutenant in the Spanish Air Force.
`
`3.
`
`I received a Doctorate of Philosophy and a Master's of Science from the
`
`Department of Mechanical and Aerospace Engineering at Princeton University. I received a
`
`Bachelor’s of Science and a Master’s of Science in Aeronautical Engineering from the
`
`1
`
`ANCESTRY EX. 1006
`
`1
`
`

`
`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 2 of 15 PageID #: 85
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`Universidad Politecnica in Madrid, Spain.
`
`4.
`
`I have received numerous professional distinctions and awards, including election
`
`into the U.S. National Academy of Engineering (NAE), which is one of the highest professional
`
`honors accorded an engineer in the U.S.A. I am one of 414 individuals selected as a Fellow in
`
`the National Academy of Inventors of the U.S.A., a member of the Royal Academy of
`
`Engineering of Spain, and I have received Honorary Doctorate degrees from two of the leading
`
`universities in Europe. I am a fellow of the America Physical Society, a member of the
`
`American Society of Mechanical Engineers, the Biophysical Society, and many other national
`
`and international professional societies, where I have held several leadership positions.
`
`5.
`
`I have authored over 100 peer-reviewed scientific publications on many different
`
`topics, including drug delivery systems, vascular hemodynamics, the biomechanics of cell
`
`migration, the biochemical pathways regulating the mechanics of cancer cell invasions, and the
`
`spatial-temporal distribution of traction forces exerted by amoeboid cells during migration.
`
`6.
`
`I am the named inventor of forty-six United States patents that claim novel
`
`medical devices and medical instruments and that have been used in the designs of innovative
`
`medical tools currently employed as standards of care in many medical centers throughout the
`
`United States and abroad.
`
`7.
`
`8.
`
`A copy of my curriculum vitae is attached as Exhibit A.
`
`Retention as Expert and Materials Considered
`
`I have been retained as an expert by counsel for DNA Genotek Inc. (“DNA
`
`Genotek”) regarding U.S. Patent No. 8,221,381 (“the “’381 Patent”) entitled “Container System
`
`for Releasably Storing a Substance.” A copy of the ’381 Patent is attached as Exhibit B to this
`
`declaration. For my work as an expert, I am being compensated at the rate of $375 per hour. For
`
`2
`
`2
`
`

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`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 3 of 15 PageID #: 86
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`my work providing deposition testimony and trial testimony, which typically requires that I
`
`spend significant time away from home or my office, I am compensated at a rate between $500
`
`and $600 per hour. My compensation is not contingent upon the opinions I reach, nor on the
`
`outcome of any legal action, mediation, arbitration, or the amount or terms of any settlement of
`
`the underlying legal cause.
`
`9.
`
`I have carefully reviewed the ’381 Patent. I have also physically examined in my
`
`office the Spectrum DNA Saliva Collection Kit with Solution for DNA Preservation (the
`
`“Spectrum Product”). I also have examined a similar saliva collection device with packaging
`
`indicating that it is made by Ancestry.com DNA LLC, which is nearly identical to the Spectrum
`
`Product with minor differences that are not material to my infringement analysis below. Counsel
`
`for DNA Genotek has provided me with photos of the Spectrum Product that I personally
`
`inspected in my office. I have also viewed pictures and materials depicting the Spectrum
`
`Product on Spectrum’s website, www.spectrum-dna.com.
`
`10.
`
`Spectrum’s website includes several pictures of the Spectrum Product, along with
`
`a Material Safety Data Sheet, attached as Exhibit C, a Marketing Sheet, attached as Exhibit D,
`
`and Instructions for Use, attached as Exhibit E.
`
`11.
`
`I compared the Spectrum Product to Claim 1 of the ’381 Patent, as well as to the
`
`embodiments described in the ’381 Patent. I understand that the relevant inquiry I have been
`
`asked to perform is a comparison between the Spectrum Product and the claims of the ’381
`
`Patent, as opposed to a comparison between the Spectrum Product and any product manufactured
`
`by DNA Genotek.
`
`12.
`
`Counsel for DNA Genotek asked me to consider the claims of the ’381 Patent and
`
`opine whether the examined Spectrum Product infringes any claims of the ’381 Patent. I have
`
`3
`
`3
`
`

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`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 4 of 15 PageID #: 87
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`been informed by counsel, and I understand, that a product infringes if every limitation recited in
`
`the claim is literally found in the accused device. Alternatively, I understand that if a claim
`
`limitation is not literally present in the accused device, there may nevertheless be infringement if
`
`the accused device contains elements that are equivalent to the claim limitation not literally met.
`
`I have been informed by counsel, and I understand that, this alternative means of finding
`
`infringement is called infringement under the “doctrine of equivalents.” I understand that, to
`
`find infringement under the doctrine of equivalents, courts consider whether there are
`
`“insubstantial differences” between a claim limitation that is not literally met and an element in
`
`the accused device corresponding to the missing claim limitation. I am informed that one way to
`
`determine whether the differences are insubstantial under the doctrine of equivalents is to use a
`
`“function-way-result” test. Under that test, an element in the accused product meets the claim
`
`limitation if it performs substantially the same function in substantially the same way to achieve
`
`substantially the same result as the claim limitation.
`
`13.
`
`The ’381 Patent claims a device that stores a “substance” (e.g., a liquid
`
`preservative) in a “lid” compartment before a “sample” (e.g., human saliva) is collected in a
`
`separate “vial” component. This two component design differs from other saliva collection
`
`devices on the market because the invention in the ‘381 Patent stores the “substance” or
`
`preservative incorporated within the device itself, as opposed to storing it in a separate container.
`
`When the vial and lid of the patented invention are joined, the “substance” is released, mixing
`
`the “substance” and the “sample” together. Other saliva collection devices on the market contain
`
`only a single compartment for collecting saliva. Users must manually add a liquid preservative
`
`to the saliva sample from a separate container. For example, the DNAgard Saliva Device
`
`(depicted below) requires a user to add a liquid preservative from a small dropper into the
`
`4
`
`4
`
`

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`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 5 of 15 PageID #: 88
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`collection tube.
`
`Similarly, the Norgen Saliva DNA Device (depicted below) requires a user to collect saliva in a
`
`collection tube and then squeeze the liquid preservative out of a small plastic ampule.
`
`14.
`
`The devices described in the ’381 Patent have advantages over these above
`
`devices, such as a decreased potential for sample contamination and an effective way of mixing
`
`the liquid preservative with the saliva sample.
`
`5
`
`5
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`

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`Infringement Analysis
`
`15.
`
`Based on my understanding of the law, as explained to me by counsel, and based
`
`upon my consideration of the 38] Patent and the Spectrum Product, it is my opinion that the
`
`Spectrum Product infringes at least Claim 1 of the ’381 Patent. A claim chart, attached as
`
`Exhibit F, compares the elements of the Spectrum Product to each claim limitation in Claim 1 of
`
`the ‘381 Patent. The Spectrum Product infringes the ’381 Patent because it literally meets each
`
`claim limitation in Claim 1. To the extent that there is not literal infringement, the Spectrum
`
`Product infringes under the doctrine of equivalents.
`
`16.
`
`Claim 1 of the 38] Patent identifies the following limitations:
`
`U.S. 8,221,381 — Claim 1
`
`1. A container system for releasably storing a substance, comprising:
`
`a) a vial comprising
`
`a first open end for receiving a sample,
`
`a second end comprising a sample storage chamber and
`
`a piercing member,
`
`wherein said piercing member comprises a side wall, a first
`cutting edge extending from a first pointed comer to a second comer
`that defines the intersection between said cutting edge and said side
`wall; and
`
`b) a lid configured to removably engage said vial, said lid comprising
`
`a reservoir for holding the substance, and
`
`6
`
`

`
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`U.S. 8,221,381 — Claim 1
`
`a pierceable membrane sealing the substance within said reservoir,
`
`
`
`wherein, when said system is closed by removable engagement of said
`vial with said lid, said vial and said lid are movable to a piercing
`position in which the piercing member disrupts the pierceable
`membrane to allow fluid commlmication between said reservoir and
`
`said chamber,
`
`wherein the chamber is sealed against leakage to the outside of the
`container system in the piercing position.
`
`The Spectrum Product meets each of these limitations.
`
`17.
`
`The first limitation of Claim 1 of the ’381 Patent is a container system for
`
`releasably storing a substance. The full name of the Spectrum Product, according to
`
`Spectrum’s Material Safety Data Sheet, is “Saliva Collection Kit with Solution for DNA
`
`Preservation.” Exhibit C.) The Instructions for Use tell users to tighten the lid to “release
`
`stabilizing fluid” after filling the collection tube with saliva. (Exhibit E.) Because Spectrum
`
`describes the Spectrum Product as a “collection kit” that “release[s] stabilizing fluid,” it satisfies
`
`the requirement that it be “a container system for releasably storing a substance.”
`
`18.
`
`Claim 1 requires that the container system comprises a vial comprising a first
`
`open end for receiving a sample. The Spectrum Product has a filial” that includes a collection
`
`tube. The collection tube has a first open end for receiving a sample.
`
`7
`
`

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`J-
`
`ACT\\lI\T\ON CODE
`
`A user of the Spectrum Product places a funnel on the collection tube and spits into the open end
`
`in order to fill the collection tube with a sample, which in this case, is the user’s saliva. Spectrum
`
`packages the device such that the user receives the collection tube with the funnel aheady in
`
`place on the collection tube.
`
`
`
`19.
`
`The next limitation of Claim 1 is a second end comprising a sample storage
`
`chamber. The Spectrum Product meets this lin1itatio11. The Spectrum Product has a “floor”
`
`within the collection tube that forms an end and a sample storage chamber.
`
`ll CD11
`
`AC'\'\\lI-\'\'\ON CODE
`
`Second
`End
`
`8
`
`

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`20.
`
`The next limitation of Claim 1 is a piercing member. The “piercing member” of
`
`the Spectrum Product is a cylinder housing three teeth with pointed corners or blades arranged in
`
`a circular fashion. This pict1u‘e of the Spectrum Prod11ct’s piercing member was taken afier it was
`
`pulled out of the lid of the Spectrum Product.
`
`21.
`
`The piercing member is located in the bottom of the lid apart from the collection
`
`tube when the Spectrum Product is shipped in its packaging. When in use, the piercing member
`
`becomes wedged in the top of the collection tube, completing the claimed “vial.”
`
`A<f;TI\/ATION CODE
`
`
`
`pp. 10 j
`
`Piercing
`member
`
`22.
`
`To the extent the “piercing member” claim limitation is not literally met, the
`
`limitation is met rnrder the doctrine of equivalents because Spectmm’s “piercing member”
`
`9
`
`

`
`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 10 of 15 PageID #: 93
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`performs the same function as the ’381 Patent’s “piercing member,” in substantially the same
`
`way, to achieve substantially the same result. The specification of the ‘381 Patent provides an
`
`example showing the function of the piercing members and the way they work to achieve a
`
`result.
`
`In operation, in moving to the piercing position, pointed end 31 of
`piercing member 6 is brought into contact with pierceable
`membrane 160 and pierces pierceable membrane 160. Continued
`twisting moves cutting edge 32 through pierceable membrane 160,
`disrupting pierceable membrane 160, and thereby producing an
`opening in the sealing membrane to enable the substance to enter
`chamber 2. It will be clear that if more than one piercing member
`is present, less twisting of lid 100 and vial 1 is required to generate
`an opening. When three piercing members are present, a suitable
`opening is obtainable in about one quarter of a turn. Desirably,
`pierceable membrane 160 is not completely removed from sealing
`surface 106. Thus, in the piercing position, piercing member 6
`disrupts pierceable membrane 160 to allow fluid communication
`between reservoir 102 and chamber 2.
`
`(’381 Patent, Col. 7:18-33.)
`
`23.
`
`The function of the claimed “piercing member” is to “disrupt,” or cut open the
`
`seal in the lid and release the preservative. Stated in the context of the claim language, the
`
`function is to cut open the “pierceable membrane,” which is the boundary of the “reservoir”
`
`storing the “substance.” The Spectrum Product’s piercing member performs that same function.
`
`The way it performs the piercing or cutting function is by pushing the teeth with pointed corners
`
`into contact with the membrane Using the words of Claim 1, the way it performs the cutting
`
`function is to press the “pointed corner” and “cutting edge” of the “piercing member” against the
`
`“pierceable membrane,” causing the “pierceable membrane” to tear and the “substance” (e.g.,
`
`preservative) to flow through the membrane. The result in each is the same. The “substance”
`
`flows from the lid to the sample storage area so the “substance” and “sample” combine. There
`
`are no differences, and certainly no “substantial” differences, between the claimed “piercing
`
`10
`
`10
`
`

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`Case 1:15—cv—OO661—SLR Document 10 Filed 08/24/15 Page 11 of 15 Page|D #: 94
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`member” and the depicted piercing member in the Spectnnn Product. Accordingly, the
`
`Spectnun Product has a ‘Vial comprising .
`
`.
`
`. a piercing member.”
`
`24.
`
`The next limitation of Claim 1 is
`
`that the piercing member comprises a side
`
`wall, a first cutting edge extending from a first
`
`pointed corner to a second corner that defines
`
`the intersection between said cutting edge and
`
`said side wall. The Spectrum Product meets this
`
`limitation. The piercing member of the Spectrum
`
`Product has two pointed teeth that form a cutting
`
`edge extending from a fn‘st pointed corner to a
`
`First
`pointed
`
`°°"‘e'
`Cutting
`edge
`
`d
`
`S
`ogrcgoer:
`
`Side
`wall
`
`second comer, with the first corner at a higher elevation than the second one. The path from the
`
`first poi11ted corner to the second corner defmes the intersection between the cutting edge and the
`
`side wall. Regarding the “pointed corner,” the above pict1u'e shows that it is pointed. Moreover,
`
`I inspected the Spectrinn Product and confirmed with my fmgertip that the comer is pointed and
`
`that the first corner is elevated with respect to the second one. I also inspected the drawings
`
`accompanying PCT Patent Application No. W0 2015/017701 Al (“the ’70l Application”) and
`
`U.S. Provisional Application No. 61/861,329. filed 011 August 1, 2013 (“the ’329 Application”),
`
`entitled “Sample Collection Device,” which lists Federico Gaeta as an inventor. (Exhibits G
`
`and H.) Mr. Gaeta is listed as the author of Spectrum’s Material Data Safety Sheet. (Exhibit C.)
`
`I assume for purposes of considering this claim limitation that the drawings of the ‘70l
`
`Application depict the Spectrum Product’s piercing member. The ‘70l Application and the ‘329
`
`Application refer to the Spectrtmi Piercing Member as a “piercing insert 600.” Figure 6 of the
`
`11
`
`ll
`
`11
`
`

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`‘329 Application is pasted below and shows that Spect1um’s “piercing insert 600” has teeth with
`
`the required “pointed comer.”
`
`600
`
`Figure 6
`
`25.
`
`The next limitation of Claim 1 is a lid configured to removably engage said
`
`vial. The Spectrum Product meets this limitation. In operation, a user places the lid on the
`
`collection tube after filling the sample storage area with saliva. When the Spectrum Product
`
`arrives at the lab, the lab staff removes the lid and assesses the sample.
`
`26.
`
`The next limitation of Claim 1 is that the lid comprises a reservoir for holding
`
`the substance. The Spectrum Product’s lid contains a reservoir for holding what Spectrum calls
`
`a “stabilizing fluid.” (Exhibit E.) Before the Spectrum product is used, the stabilizing fluid
`
`(e.g., DNA preservative) is stored within the lid.
`
`12
`
`12
`
`12
`
`

`
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`27.
`
`The next limitation of Claim 1 discloses a pierceable membrane sealing the
`
`substance within said reservoir. The part of the Spectrum Product depicted below is a lid with
`
`a foil seal. Other embodiments have a clear seal. The seal serves as a “pierceable membrane.”
`
`The “pierceable membrane” is “inert,” seals the “substance” within the “reservoir,” and when the
`
`teeth from the “piercing member” press against and puncture the “pierceable membrane,” the
`
`liq11id substance is released. The Spectrum Product meets this limitation.
`
`13
`
`13
`
`13
`
`

`
`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 14 of 15 PageID #: 97
`
`28.
`
`The next limitation of Claim 1 is that when said system is closed by removable
`
`engagement of said vial with said lid, said vial and said lid are movable to a piercing
`
`position in which the piercing member disrupts the pierceable membrane to allow fluid
`
`communication between said reservoir and said chamber. When the Spectrum Product lid is
`
`placed on the collection tube, the piercing member wedges in the collection tube and is then
`
`pushed up through the lid to the foil membrane (an “inert” membrane), causing the stabilizing
`
`fluid to flow through the pierced membrane and into the sample storage area. Accordingly, the
`
`Spectrum Product meets this claim limitation.
`
`29.
`
`The final limitation of Claim 1 is that the chamber is sealed against leakage to
`
`the outside of the container system in the piercing position. When the Spectrum Product is
`
`moved into the piercing position, the threading on the lid meshes with the threading on the
`
`collection tube, thus creating a seal against leakage. Accordingly, the Spectrum Product meets
`
`14
`
`14
`
`

`
`Case 1:15-cv-00661-SLR Document 10 Filed 08/24/15 Page 15 of 15 PageID #: 98
`
`this claim limitation.
`
`30.
`
`In my analysis of the Spectrum Product, I find evidence demonstrating that each
`
`and every limitation of Claim 1 of the ’381 Patent is present. The attached claim chart,
`
`Exhibit F, shows that each limitation is met.
`
`I declare under penalty of perjury of the laws of the United States that the foregoing is
`
`true and correct.
`
`Executed this 24th day of August, 2015, at San Diego, California.
`
`By:
` Juan C. Lasheras, Ph.D.
`
`15
`
`15
`
`

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`
`EXHIBIT A
`
`
`
`EXHIBIT AEXHIBIT A
`
`
`
`
`
`1616
`
`16
`
`

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`Case 1:15-cv-00661-SLR Document 10-1 Filed 08/24/15 Page 2 of 139 PageID #: 100
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`
`JUAN CARLOS LASHERAS
`
`Departments of Mechanical and Aerospace Engineering and Bioengineering
`University of California, San Diego
`La Jolla, California 92093-0411
`Telephone: (858) 534-5437 Office, (858) 534-4368 Laboratory
`e-mail: lasheras@ucsd.edu
`http://maeresearch.ucsd.edu/lasheras/
`
`Home Address: 6898 Via Estrada, La Jolla, CA 92037
`(858) 551-8889, home; (858) 449-3768, cell
`
`
`EDUCATION
`
`Ph.D. in Mechanical and Aerospace Engineering. Princeton University (1982).
`M.S.E. in Mechanical and Aerospace Engineering. Princeton University (1979).
`Ingeniero Superior Aeronáutico (BS/MS). E.T.S. Ingenieros Aeronáuticos
`
`Universidad Politécnica de Madrid. Madrid, Spain (1975).
`
`PROFESSIONAL EXPERIENCE
`
`2013
`2012
`2009 - Present
`
`Interim Dean. Jacobs School of Engineering. UCSD
`Acting Dean. Jacobs School of Engineering. UCSD
`Director of the Center for Medical Devices and Instrumentation. Institute
`of Engineering in Medicine. UCSD
`Distinguished Professor of Bioengineering (Affiliate). UCSD
`Stanford S. and Beverly P. Penner Endowed Chair Professor of
`Engineering and Applied Sciences. UCSD
`Distinguished Professor of Mechanical and Aerospace Engineering.
`UCSD
`
`Chairman of the Department of Mechanical and Aerospace Engineering.
`UCSD
`
`
`Professor and Vice-Chair of the Department of Applied Mechanics and
`Engineering Sciences (AMES). UCSD
`Co-Founder and Scientific Adviser, INNERCOOL Therapies. San Diego,
`California.
`Professeur Associé. Institut de Mecanique de Grenoble. Université J.
`Fourier. Grenoble I, France.
`Associate Professor. Department of Mechanical Engineering
`University of Southern California. Los Angeles, CA 90089-1453.
`Assistant Professor. Department of Mechanical Engineering
`University of Southern California. Los Angeles, CA 90089-1453.
`Research Scientist. Koninklijke/Shell-Laboratorium - Amsterdam
`(Royal-Dutch/Shell - Laboratory - Amsterdam) Shell International
`Research B.V. Bathuisweg 3, 1003 AA Amsterdam, The Netherlands.
`Profesor Adjunto Interino (Lecturer). E.T.S. Ingenieros Aeronáuticos
`
` 1
`
`2008 - Present
`2007 - Present
`
`2007 - Present
`
`1999 - 2004
`
`
`1991 - 1998
`
`1997 - 2007
`
`1991, 1995
`
`1988 - 1991
`
`
`1983 - 1988
`
`
`1982 - 1983
`
`1976-1977
`
`
`
`
`
`
`
`
`
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`
`
`
`
`17
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`

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`Case 1:15-cv-00661-SLR Document 10-1 Filed 08/24/15 Page 3 of 139 PageID #: 101
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`
`
`
`Universidad Politécnica de Madrid. Madrid, Spain.
`2nd Lieutenant. Air Force of Spain.
`Director. Academia Lasheras. San Javier, Murcia, Spain.
`
`
`
`1975-1976
`1970-1975
`
`PROFESSIONAL DISTINCTIONS AND AWARDS
`
`2014
`2012
`2013-15
`2012
`
`2012/13
`
`2011
`
`2011
`
`2010
`
`2010-2011
`
`2007-2010
`
`2009
`
`2008
`
`2003
`
`2001
`
`2000
`1999
`
`1997-2000
`
`1997-2000
`
`2000
`
`
`
`Elected Fellow of the National Academy of Inventors of the USA
`Elected Member of the National Academy of Engineering of the USA
`Chair of Excellence Professorship. Universidad Carlos III, Madrid, Spain
`Chairman of the 65th Annual Meeting of the American Physical
`Society/DFD. San Diego, CA. November 2012.
`Invited to deliver the 2012/13 Distinguished Midwest Mechanics Seminar
`Series at 10 leading Midwest Universities: the University of Michigan, the
`University of Minnesota. Illinois Institute of Technology, Iowa State
`University, Michigan State University, Northwestern University, Purdue
`University, the University of Illinois at Urbana-Champaign, the University
`of Notre Dame and the University of Wisconsin, Madison.
`Doctor Honoris Causa (Honorary Doctor Degree). Universidad
`Politécnica de Madrid, Spain. October 3rd, 2011.
`Doctor Honoris Causa (Honorary Doctor Degree). Universidad
`Carlos III de Madrid, Spain, January 29th, 2011.
`Director’s Award for Exemplary Service to the Nation. 2010 Gulf of
`Mexico, Deepwater Horizon Oil Spill Response. United States Geological
`Service (USGS)
`Chairman of the American Physical Society/Division of Fluid
`Dynamics.
`Chairman of the Board of Advisors of the Institute of Biomedical
`Engineering. Universidad Carlos III de Madrid, Spain.
`Chairman of the American Physical Society/Division of Fluid
`Dynamics.
`Vice-Chair of the American Physical Society/Division of
`Fluid Dynamics.
`Breakthrough Innovation in Medical Sciences Award, given by
`BIOCOM and BIOSECTOR of Southern California. (Shared with
`Mike Magers. InnerCool Therapies).
`Chairman of the 54th Annual Meeting of the American Physical
`Society/DFD
`Elected Fellow of the American Physical Society (APS).
`Elected Member of the Real Academia de Ingeniería de España
`(Royal Academy of Engineering of Spain).
`
`
`Secretary/Treasurer of the American Physical Society/
`Division of Fluid Dynamics.
`
`
`
`
`Elected Member of the Council of the American Physical Society/
`Division of Fluid Dynamics.
`
`
`Best Teacher of the Year Award in Mechanical Engineering. Jacobs
`School of Engineering. UCSD
`
`
`
`
`
`
`
`
`
`
`
`
`
` 2
`
`18
`
`

`
`Case 1:15-cv-00661-SLR Document 10-1 Filed 08/24/15 Page 4 of 139 PageID #: 102
`
`
`1998
`
`1996
`
`1995
`
`1994
`
`1990
`
`
`
`
`Best Teacher of the Year Award in Mechanical Engineering. Jacobs
`School of Engineering. UCSD
`Best Teacher of the Year Award in Mechanical Engineering. Jacobs
`School of Engineering. UCSD
`Best Teacher of the Year Award in Mechanical Engineering. Jacobs
`School of Engineering. UCSD
`
`
`Jacobs School of Engineering Annual Teaching Award. School-wide
`annual teaching award given by the Tau Beta Pi Engineering Honor
`Society, UCSD.
`F.N. Frenkiel Award for Fluid Dynamics. American Physical Society.
`(Shared with B.J. Lázaro).
`
`
`
`
`
`George Van Ness-Lothrop Fellowship.
`1980-1981
`1977-78, 1978-79 Guggenheim Fellowship
`
`
`
`
`
`
`
`Memberships of Professional Societies
`
`2015-present
`2012-present
`1999-present
`
`
`
`
`
`
`
`
`
`Fellow of the National Academy of Inventors (NAI) of the USA
`Member of the National Academy of Engineering (NAE) of the USA.
`Member of the Royal Academy of Engineering of Spain (Real
`Academia de Ingeniería de España)
`Fellow of American Physical Society (APS).
`
`
`American Institute for Aeronautics and Astronautics (AIAA).
`American Society of Mechanical Engineers (ASME).
`
`The Combustion Institute.
`
`
`
`
`
`
`1983-present
`1983-present
`1977-present
`1977-present
`
`Current Editorial Boards
`
`2010-present
`2012-present
`
`2012
`
`
`2013-present
`
`2013, 2014, 2015.
`2015
`
`
`
`
`Physical Review X. Editorial Board
`
`Journal of Fluid Mechanics. Associate Editor
`Annual Reviews of Fluid Mechanics. Editorial Board
`Review of Scientific Instruments. Editorial Board
`Guest Editor. Proc. of the Nat. Academy of Sciences of the USA
`Guest Editor. PLOS Computational Biology
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` 3
`
`19
`
`

`
`Case 1:15-cv-00661-SLR Document 10-1 Filed 08/24/15 Page 5 of 139 PageID #: 103
`
`
`
`Juan C. Lasheras
`Bibliography
`
`
`A. PRIMARY PUBLISHED WORK
`http://scholar.google.com/citations?hl=en&user=p__O--YAAAAJ&view_op=list_works&is_public_preview=1
`Citations = 6,645; h-index = 46; i10-index = 100
`
`
`I.
`
`Refereed Journal Articles
`
`
`1. J. C. Lasheras, A. C. Fernández-Pello and F. L. Dryer, “Initial Observations on the Free Droplet
`Combustion Characteristics of Water-in-Fuel Emulsions”, Combustion Science and Technology,
`Vol. 21, pp. 1-14, (1979).
`2. J. C. Lasheras, A. C. Fernández-Pello and F. L. Dryer, “Experimental Observation on the
`Disruptive Combustion of Free Droplets of Multicomponent Fuels”, Combustion Science and
`Technology, Vol. 22, pp. 195-210, (1980).
`3. J. C. Lasheras, A. C. Fernández-Pello and F. L. Dryer, “On the Disruptive Burning of Alcohol/n-
`Paraffin Solutions and Emulsions.” 18th International Symposium on Combustion, The
`Combustion Institute, pp. 293-307, (1981).
`4. J. C. Lasheras, I. M. Kennedy and F. L. Dryer, “Burning of Distillate Fuel Droplets Containing
`Alcohol or Water: Effect of Additive Concentration.” Combustion Science and Technology,
`Vol. 26, pp. 161-169, (1981).
`5. J. C. Lasheras, L. T. Yap and F. L. Dryer, “Effect of the Ambient Pressure on the Explosive
`Burning of Emulsified and Multi-component Fuel Droplets.” 20th International Symposium on
`Combustion. The Combustion Institute, pp. 1761-1772, (1985).
`6. J. C. Lasheras. “Response of a Plane, Free Shear-Layer to a Localized Three-Dimensional
`Perturbation”. Physics of Fluids, Vol. 28, No. 9, pp. 2638, (1985).
`7. J. C. Lasheras, J. S. Cho and T. Maxworthy, “On the Origin and Scale of Streamwise Vortical
`Structures in a Plane, Free Shear-Layer”, Journal of Fluid Mechanics, Vol. 172, pp. 231-258,
`(1986).
`8. J. C. Lasheras and T. Maxworthy, “Structure of the Vorticity Field in a Plane Free Shear-
`Layers.” Turbulent Shear Flows 5. Springer-Verlag, (Berlin, Heidelberg. Germany). Durst,
`Launder, Schmidt Editors, pp. 124-168, (1987).
`9. E. Meiburg and J. C. Lasheras, “Comparison between Experiments and Numerical Simulations
`of Three-Dimensional Plane Wakes.” Physics of Fluids, Vol. 30, No. 3, pp. 623-625, (1987).
`10. G. A. Lawrence, J. C. Lasheras and F. K. Browand, “The Stability of Two-layer Shear Flow.”
`Proceedings of the Sixth Symposium on Turbulent Shear Flows, 12, 3, 1. Toulouse, France,
`September 7-9, (1987).
`11. E. Meiburg, J. C. Lasheras and W. T. Ashurst, “Topology of the Vorticity Field in Three-
`Dimensional Shear Layers and Wakes.” Journal of Fluid Dynamics Research. Vol. 3, pp. 140-
`148, (1988).
`12. E. Meiburg and J. C. Lasheras. “Experimental and Numerical Investigation of the Three-
`Dimensional Transition in Plane Wakes.” Journal of Fluid Mechanics, Vol. 190, pp. 1-37,
`(1988).
`13. J. C. Lasheras and H. Choi, “Three-Dimensional Instability of a Plane, Free Shear Layer: An
`Experimental Study on the Formation and Evolution of Streamwise Vortices.” Journal of Fluid
`Mechanics, Vol. 189, pp. 53-86, (1988).
`
`
`
` 4
`
`20
`
`

`
`Case 1:15-cv-00661-SLR Document 10-1 Filed 08/24/15 Page 6 of 139 PageID #: 104
`
`
`14. E. Meiburg and J. C. Lasheras. “Experimental and Numerical Investigation of the Three-
`Dimensional Transition in Plane Wakes.” Journal of Fluid Mechanics, Vol. 190, pp. 1-37,
`(1988).
`15. B. J. Lázaro and J. C. Lasheras. “Droplet Dispersion and Transport Mechanisms in a Turbulent,
`Free Shear-Layer.” 22nd International Symposium on Combustion. The Combustion Institute, pp.
`1981-1988, (1988).
`16. B. J. Lázaro and J. C. Lasheras. “Particle Dispersion in a Turbulent, Plane, Free Shear Layer.”
`Physics of Fluids A, Vol. 1, No. 6, pp 1035-1044, (1989).
`17. J. C. Lasheras and E. Meiburg. “Three-dimensional Vorticity Dynamics in the Near Wake
`Behind Two-dimensional Bodies.” Advances in Turbulence 2. Springer-Verlag, (Berlin,
`Heidelberg, Germany). Fernholz and Fiedler, Editors. pp. 62-69, (1989).
`18. J. C. Lasheras and E. Meiburg. “Three-Dimensional Vorticity Modes in the Wake of a Flat
`Plate.” Physics of Fluids A, Vol. 2, No. 3, pp. 371-380, (1990).
`19. E. Meiburg and J. C. Lasheras, “Free Shear Flows: Symmetries and Topological of the Vorticity
`Field.” Topological Fluid Mechanics. Cambridge University Press, (Cambridge, England).
`Moffatt and Tsinobere Editors, pp. 678-689, (1990).
`20. E. Meiburg, J. C. Lasheras and J. Martin, “Experimental and Numerical Analysis of the Three-
`dimensional Evolution of an Axisymmetric Jet.” Turbulent Shear Flows 7, Springer-Verlag,
`(Berlin, Heidelberg. Germany). Durst, Launder, Schmidt, Editors, pp 195-208, (1991).
`21. J

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