US Patent and Trademark Office
`_________________________________________
`
`Dynamic Air Inc.
`v.
`M-I Drilling Fluids UK Ltd.
`
`_________________________________________
`
`Deposition of:
`Stuart Brown, Ph.D. - Volume 1
`November 9, 2016
`
`DYNAMIC AIR INC.
`EXHIBIT 1108
`
`
`_________________________________________
`
`Dynamic Air Inc.
`v.
`M-I Drilling Fluids UK Ltd.
`
`_________________________________________
`
`Deposition of:
`Stuart Brown, Ph.D. - Volume 1
`November 9, 2016
`
`DYNAMIC AIR INC.
`EXHIBIT 1108
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`------------------------------------------------
`DYNAMIC AIR INC.,
` Petitioner,
`v.
`M-I DRILLING FLUIDS UK LTD.,
` Patent Owner.
`
`Case IPR2016-00256
`------------------------------------------------
`
`DEPOSITION OF
`Stuart B. Brown, Ph.D. - Volume 1
`November 9, 2016
`Charlotte, North Carolina
`Lead: Alan Carlson, Esquire
`Firm: Carlson Caspers Vandenburgh
`
`FINAL COPY
`JANE ROSE REPORTING 1-800-825-3341
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`JANE ROSE REPORTING
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`National Court-Reporting Coverage
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`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 2
`
`ATTORNEYS FOR PETITIONER
` ALAN G. CARLSON, ESQUIRE
` TODD S. WERNER, ESQUIRE
` Carlson, Caspers, Vandenburgh,
` Lindquist and Schuman, P.A.
` 225 South Sixth Street, Suite 4200
` Minneapolis, MN 55402
` 612.436.9600
` acarlson@carlsoncaspers.com
` twerner@carlsoncaspers.com
`
`ATTORNEYS FOR PATENT OWNER
` BRUCE J. ROSE, ESQUIRE
` CHRISTOPHER TL DOUGLAS, ESQUIRE
` Alston & Bird LLP
` Bank of America Plaza
` 101 South Tryon Street, Suite 4000
` Charlotte, NC 28280-4000
` 704.444.1000
` bruce.rose@alston.com
` christopher.douglas@alston.com
`
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`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
` TABLE OF CONTENTS
`
`Witness: Stuart B. Brown, Ph.D.
`
`Page 3
`
`Examination
`By Mr. Carlson........................... Page 4
`
`Reporter Certificate..................... Page 229
`
`Notice to Read and Sign.................. Page 231
`
`Index of Exhibits........................ Page 233
`
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`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 4
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` * * *
` Charlotte, North Carolina
` 9:10 a.m.
` * * *
` STUART B. BROWN, Ph.D.,
` having been first duly sworn, was examined and
` testified as follows:
` EXAMINATION
`BY MR. CARLSON:
` Q. Would you state your name, please.
` A. Stuart Brown.
` Q. Are you the Stuart Brown who filed some
`declarations in the matter in the patent office that
`is entitled "Dynamic Air versus M-I Drilling"?
` A. I am.
`
` (EXHIBIT 2015, Curriculum Vitae of
` Stuart B. Brown, Ph.D., was marked for
` identification.)
`
`BY MR. CARLSON:
` Q. I'm going to show you a document marked
`Exhibit 2015. Is that your CV?
` MR. ROSE: Counsel, do you have another
` set for -- for us or --
`
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`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 5
` MR. CARLSON: Oh, well, it should be in
` there.
` MR. ROSE: Thank you.
` THE WITNESS: Yes, it is.
`BY MR. CARLSON:
` Q. When was the last time this CV was
`modified?
` A. You know, the best I can say is probably
`sometime this summer.
` Q. Was it modified to take into account the
`issues that are involved in this lawsuit?
` A. No.
` Q. So this is a CV that you would have used
`for a number of your other cases that are on Page 11
`of the document; is that correct?
` A. I don't know, because I don't have -- I
`see that -- the time that I was involved in these
`matters. I mean, I update my CV from time to time.
`So I can't say.
` Q. Okay. But you can say that this CV was
`not updated to take into account the issues that
`were involved in this matter, correct?
` A. Yes. To the best of my knowledge,
`that's correct.
` Q. All right. Let me get an understanding
`
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`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 6
`of your background. When you were at Stanford, were
`you working?
` A. Only for a little bit of that period. I
`was doing two master's at the same time. I was
`doing my MBA and my master's in mechanical
`engineering. And just because of the course
`requirements, I couldn't do it all in precisely two
`years, and I needed another quarter of work to
`finish my master's in engineering. And I worked
`part-time during the preceding summer and then
`part-time during that quarter.
` Q. Did you have any work in the
`pneumatic-conveying field?
` A. No, not at that time.
` Q. Okay. Now, you get your MBA and MS in
`1979, 1980. And -- and next you got a Ph.D. in '87.
`So did you work then between 1980 and 1987?
` A. I did.
` Q. And who did you work for?
` A. I worked for an engineering consulting
`firm in -- near Stanford, actually, called
`Failure Analysis Associates.
` Q. And that's the only company you worked
`for during that time frame?
` A. Yes.
`
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`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 7
`
` Q. And what was their business?
` A. Well, they did predominantly consulting
`in the area of what I would call fracture mechanics.
`The founder of the company, Alan Tetelman, was one
`of the founders of the field of fracture mechanics,
`and I was a junior-level engineer assisting with the
`projects at that time.
` Q. So did you work for them while you were
`doing your work at MIT?
` A. No.
` Q. So did you leave them, then go to MIT
`full-time?
` A. Yes.
` Q. And what year did you leave Failure
`Analysis?
` A. I left Failure Analysis in the fall of
`1982.
` Q. Were you at MIT from '82 to '87?
` A. I was.
` Q. And while you were there, you were
`working on obtaining your Ph.D.; is that correct?
` A. That's correct.
` Q. Were you teaching as well?
` A. I -- I worked as a teaching assistant
`for the first year I was there. After that period,
`
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`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 8
`
`I was funded under sponsored research.
` Q. Did you write a thesis?
` A. I did.
` Q. And what was the subject of that?
` A. The title of the thesis was "An Internal
`Variable Constitutive Model for the Hot Working of
`Metals."
` Q. What was your hope the commercial
`application would be of that work?
` A. That's a very broad question. At the
`time, my expectation was to advance the field of
`knowledge in understanding the nonlinear flow
`behavior of metals at high temperatures.
` Q. What were your expectations of a
`commercial application for that knowledge?
` MR. ROSE: Objection. Form.
` THE WITNESS: Well, I think, as I said,
` I'm -- I'm not sure I had commercial
` expectations. My agenda was -- typically,
` with a Ph.D., the agenda is to provide a -- an
` advance in the knowledge in some field.
`BY MR. CARLSON:
` Q. Well, let me ask it this way then: At
`that time, when you were advancing the knowledge in
`that field, was there already an application for
`
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`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 9
`
`that sort of understanding and knowledge?
` A. Yes. I believe so.
` Q. And -- and where was that? What field?
` A. It would be in two fields. One is
`specifically the behavior of metals at high
`temperatures. And the other one was the use of the
`mathematical structure which came out of that thesis
`in modeling other nonlinear materials.
` Q. When you got your Ph.D. in '87, did you
`join Exponent at that time?
` A. No.
` Q. What year did you join Exponent?
` A. I joined Exponent in 1995.
` Q. So from 1987 to 1995 you were on the
`faculty at MIT, correct?
` A. Correct.
` Q. And being on the faculty, you taught
`courses?
` A. Yes.
` Q. To undergraduates and -- and -- and
`graduate students as well?
` A. Yes.
` Q. Did you do anything to consult in
`industry at that time, '87 to '95?
` A. Yes.
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`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 10
` Q. Did you do any consulting in industry
`relating to the pneumatic transfer of materials?
` A. Yes.
` Q. Who was the client?
` A. This would have been the Hoeganaes
`Corporation.
` Q. Would you spell that.
` A. I -- if I can. H-O-E -- this may be
`wrong -- G-A-E-N-O-U-S [sic]. It was a company
`that -- that processed metal powders.
` Q. And when they processed these metal
`powders, did they move them periodically by
`pneumatic conveyance?
` A. Yes.
` Q. So those are pneumatic-conveyance
`systems designed by other people that your client
`was using?
` A. I -- I don't recall. I don't recall
`whether they designed them or whether they purchased
`them from other suppliers. I don't recall.
` Q. Did you have any part in designing the
`pneumatic-conveying equipment that your client used?
` A. No.
` Q. And how were these metal powers -- or
`powders -- I'm sorry -- pneumatically conveyed?
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`Stuart Brown, Ph.D. - Vol. 1
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`Page 11
`
` A. My -- my recollection is two ways.
`There was a system that used vacuum to collect and
`transport the powders from one location to another.
`And then, also, there were positive-pressure
`conveyance systems where the powder was inserted
`into a -- into an airstream, which conveyed the
`powders from one location to another.
` Q. Did the airstream fully surround the
`powder particles?
` A. I'm not sure if I understand the
`question. Are -- are you saying, were the powders
`surrounded by air as they moved along?
` Q. Yes.
` A. Yes.
` Q. In other words, the powders weren't on
`the bottom of the pipe or the conveying means and --
`and pushed along, correct?
` MR. ROSE: Objection to form.
` THE WITNESS: You know, it was -- it's
` been a long time. I don't recall.
`BY MR. CARLSON:
` Q. Okay. So you don't recall whether the
`powders were fully entrained in the air?
` A. I don't.
` Q. Is there any other client that you
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`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 12
`
`consulted with where you were exposed to the
`pneumatic transfer of materials while in the period
`of '87 to '95?
` A. Yes.
` Q. And who -- who was that client?
` A. That would be Alcoa.
` Q. And were you involved in the designing
`of pneumatic-conveying equipment in that
`application?
` A. No.
` Q. Alcoa, though, pneumatically transferred
`materials, correct?
` A. Yes.
` Q. Was that positive pressure and vacuum,
`both?
` A. No. I believe that was only vacuum.
` Q. Were the --
` What was it that was conveyed by vacuum?
` A. Plastic pellets.
` Q. Were the plastic pellets fully entrained
`in the air?
` A. Once again, this was many years ago. So
`I don't recall.
` Q. Okay. Well, let -- let me -- let me
`deal with some of the questions and answers I'll
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`Stuart Brown, Ph.D. - Vol. 1
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`Page 13
`
`be -- we'll be dealing with today.
` Have you been deposed before?
` A. Yes.
` Q. How many times?
` A. 10 to 15.
` Q. So you know that if you don't recall,
`you should just tell us that, and that will be the
`end of it. You know that, right?
` MR. ROSE: Objection to form.
` THE WITNESS: I -- my obligation is, to
` my mind, to answer the question as best I can.
` If I don't recall, I'll say, "I don't recall."
`BY MR. CARLSON:
` Q. Good.
` And if my question is unclear to you,
`will you feel free to ask me to clarify it?
` A. Yes.
` Q. Okay. Good.
` So are there any other clients that you
`consulted with in the period of '87 to '95 where you
`were exposed to pneumatic conveying?
` A. That's the two that I can remember.
` Q. Now, when you joined Exponent in 1995,
`where were you located?
` A. I was in Natick -- well, I was living in
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`
`Page 14
`Needham, Massachusetts, and I was working in Natick,
`Massachusetts. N-A-T-I-C-K.
` Q. Okay. So you were -- you were in the
`Boston area?
` A. Yes.
` Q. And -- and in what year did you join
`Ver-set (phonetic)? That's V-E-R-Y-S-T. Did I
`pronounce that correctly?
` A. We -- we say Vair-ist (phonetic).
` Q. Veryst. What year did you join them?
` A. Well, actually, I founded Veryst in the
`end of 2005, beginning of 2006.
` Q. Okay. So you were with Exponent for
`about ten years?
` A. Correct.
` Q. And during that time, were you exposed
`to pneumatic conveying of materials?
` A. Yes.
` Q. And did you have any cases where you
`were involved in the design of pneumatic-conveying
`equipment?
` A. The reason why I pause is that we were
`involved in one project involving what we call
`"tableting," which is in the making of medication
`where one takes a pharmaceutical -- pharmaceutical
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`
`Page 15
`powder and transfers that powder to a machine and
`then compresses that into tablets. And there was a
`problem with the tablets in that they were
`fracturing when they were being removed from the
`compaction dies. Part of our -- and we were hired
`to try to understand why that was happening.
` Part of our findings was that the
`pneumatic-conveyance process that they used to take
`from the bin or the -- the receptacle of
`pharmaceutical powders to transfer to the tableting
`machine was what we would call "segregating the --
`the ingredients"; that you had the active
`pharmaceutical -- there were other ingredients which
`would, what we call "bind the powders and other
`ingredients." And through the flow process, the
`heavier particles were separating from the lighter
`particles. And --
` So we made recommendations in terms of
`changing their pneumatic-conveyance process. We did
`not design the process. So I -- I think we sort of
`sit at a -- an intermediate position between design
`and recommendations for design changes.
` Q. Well --
` A. That's -- that's -- that's what we did
`in that case. And I can't recall in other instances
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`Page 16
`were we involved with pneumatic transfer where --
`where we designed or made recommendations for
`designs.
` Q. Okay. So you're saying that, with
`respect to the design of pneumatic-conveying
`equipment, the only one you can recall was this one
`application relating to the breaking up of tablets?
` MR. ROSE: Objection to form.
` THE WITNESS: Well, it was pneumatic
` conveying of the ingredients for tablets.
` But, yes, for the tableting process.
`BY MR. CARLSON:
` Q. Yeah. Okay.
` Do you remember in a general,
`big-picture way what your recommendations were with
`respect to changes in the process?
` A. I -- I -- I believe -- although my
`recollection, once again, isn't perfect, given the
`fact it was such a long time ago, I believe we
`added -- we make -- made recommendations to change
`the character of the flow occurring within the
`transfer line to encourage mixing. But, once again,
`that's a very high-level recollection from many
`years ago.
` Q. Well, what would it be that would be
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`
`Page 17
`
`changed to encourage mixing?
` A. Well, I can't recall what we recommended
`in that matter. I mean, there are different
`processes that you can follow. I don't recall
`whether any of those were specifically what we
`recommended.
` Q. Well, when the powders were being
`conveyed, and there was segregation of the
`ingredients, were these powders conveying in a
`positive pneumatic-conveyance manner?
` A. I don't recall.
` Q. When you say "positive pneumatic
`conveyance," do you mean that the air is, in a
`sense, behind the particle and pushing the particle
`in a direction that the air is flowing?
` MR. ROSE: Objection to form.
` THE WITNESS: No.
`BY MR. CARLSON:
` Q. Okay. What do you mean by "positive
`pneumatic conveying"?
` MR. ROSE: Objection to form.
` THE WITNESS: I interpret "positive
` conveying" as developing a pressure
` differential along the transfer line where the
` pressure at the beginning of the line is above
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 18
` atmospheric. Or above ambient. That -- maybe
` that's more accurate.
`BY MR. CARLSON:
` Q. In -- in your understanding of -- of
`positive conveying, is the velocity of the flow
`increased, then, by increasing the temperature even
`greater above ambient?
` A. Sir, you said "temperature."
` Q. Oh, did I? I'm sorry. I apologize.
`Let me rephrase the question.
` In a positive-conveyance system that's
`due to a change in the pressure between where it
`starts from and where you want it to go to, do you
`increase the velocity of the particles by making the
`pressure at its start point even higher?
` MR. ROSE: Objection to form.
` THE WITNESS: There are many factors
` which control air velocity. As a matter of
` general principles, if one controls all of the
` other factors associated with a particular
` conveyance system, the larger the differential
` pressure from one point to the other,
` everything else being equal, the velocity
` should increase.
`BY MR. CARLSON:
`
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 19
`
` Q. So have we dealt with the only case
`between 1995 and 2005 where you had a consulting
`project that involved the pneumatic conveying of
`materials?
` A. No.
` Q. Okay. There were others?
` A. Yes.
` Q. How many others?
` A. I can recall one other circumstance.
` Q. Okay. Would you tell me about that,
`please.
` A. That involved the pneumatic conveyance
`of forging sand.
` Q. And who was the client?
` A. Atchison Forgings. No. I'm sorry. It
`may have been Atchison Castings. I don't think they
`exist anymore.
` Q. Okay. And in that case, did you design
`any aspect of the pneumatic-conveying system?
` A. No.
` I'm sorry. I want to come back. It was
`"Atchison Castings," not "Forgings," as I recall
`now. And, once again, I don't recall the details.
`That also involved segregation of powder
`constituents as the forging sand was transported
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 20
`
`from one location to another.
` Q. Is it the case that you don't want the
`components or the constituents to segregate?
` MR. ROSE: Objection. Form.
` THE WITNESS: Not necessarily.
`BY MR. CARLSON:
` Q. Well, in this case, was that the
`problem, that they were segregating, and -- and you
`don't want them to segregate?
` A. Yes.
` Q. And by "segregation," you mean separate
`out from each other?
` A. Correct.
` Q. Okay. And sand has constituents that
`consist of what?
` MR. ROSE: Objection. Form.
` THE WITNESS: Forging sand is an
` engineered material which consists of sand and
` a -- different other powder ingredients,
` typically wax or polymers, which are used to
` make the forging molds --
`BY MR. CARLSON:
` Q. Okay.
` A. -- for subsequent casting of metals.
` Q. Well, in the -- the -- the tablet
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 21
`application, you recommend that they change the
`character of the flow to encourage mixing?
` A. Yes.
` Q. And -- and you don't recall what the
`character was that you recommended changing, though?
` A. No, I don't.
` Q. Okay. Did you -- did you make a similar
`recommendation with respect to Atchison, that they
`change the character of the flow?
` A. I -- I think we would have to, because
`that was the issue. But I just don't remember.
` Q. You don't remember what the
`recommendation was?
` A. Right.
` Q. Okay. And do you know whether, in the
`case of Atchison, some of the -- strike that.
` In the case of Atchison, was all of the
`powder entrained in an airstream?
` A. I don't recall.
` Q. Okay. Do you remember any other
`consulting that you did between '95 and '05 where
`there was an exposure to pneumatic conveying?
` A. No, not that -- sitting here, I can't
`recall anything else.
` Q. Well, let's turn now to your work
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 22
`
`with --
` A. I'm sorry. Veryst.
` Q. Veryst.
` A. Think of it as V-E-R-I-S-T.
` Q. Okay. Veryst.
` Did you have exposure to
`pneumatic-conveying systems in connection with your
`consulting for Veryst?
` A. Yes.
` Q. How many instances?
` A. Only one that I can recall.
` Q. Okay. Would you tell me about that,
`please, sir. First of all, who was the client?
` A. That would have been S.C. Johnson.
` Q. And what were they pneumatically
`conveying?
` A. That was plastic pellets as well.
` Q. And in this case, you didn't get
`involved in the design of the equipment, did you?
` A. No.
` Q. Were they having a problem, though, that
`caused you to look at their equipment?
` A. There was.
` Q. And what was their problem?
` A. They were injection-molding plastic
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 23
`components, and there is a process which takes place
`in injection molding in which involves a material
`called regrind, which is -- that when you
`injection-mold something out of plastic, there are
`portions of the molding process which don't go into
`the product. They're -- they're called "runners,"
`but you can think of it as the part of the plastic
`which goes in the molds to the cavity where the
`actual component sits, but those runners solidify as
`well. And what one frequently does is take that
`material, chop it up, and put it back into the feed
`stream virgin material rather than wasting it,
`rather than throwing it out.
` And the problem that was -- there
`were -- there were not just one problems -- one --
`there was not just one problem. But one issue with
`that was the mixing of the regrind with the virgin
`material and how it was being transported from the
`apparatus which chopped it up and was putting it
`into the feed stream of the virgin plastic material
`for subsequent molding.
` Q. And -- and you haven't identified the --
`the problem. Was it that it was not mixing well?
` A. Correct.
` Q. Okay. And did you make a recommendation
`
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 24
`
`on how to make it mix better?
` A. Yes.
` Q. Do you remember the recommendation?
` A. In that case, I think we were
`recommending mechanical agitation of the mixture to
`better blend the two feed streams.
` Q. Looking back at Exhibit 2015 in
`connection with the patents and publications, are
`any of these patents or publications dealing with
`the pneumatic conveying of materials?
` A. I did work, and as -- as you can see in
`my -- in my publication list, on compaction and
`forging of powders. I actually wrote the chapter on
`powder forging in the "Encyclopedia of Materials" in
`1994. And part of that work -- so -- so that work
`was on the compaction of powders. Meaning, once the
`powders fill a cavity, what is their behavior as
`you -- as you squish them together.
` And the compaction process is an issue
`also in pneumatic conveyance of powder materials.
`Although -- so the -- how do I say this? I'm not
`trying to be cute. The phenomena, the principles
`are the same. It wasn't associated with pneumatic
`conveyance. It was the same physical process which
`happens with powders, except I was applying it for
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 25
`
`powder compaction.
` Q. Okay. Let me go back.
` While you were -- while you were on the
`faculty of MIT and you worked for Hoeganaes and
`Alcoa, what was your role?
` A. There were different -- my role was
`different with the two clients.
` Q. Okay. Let's take Hoeganaes.
` A. For Hoeganaes, I was asked to look at
`their process stream. So that would be start to
`finish. And I would work with their engineers to
`provide suggestions to problems that they had with
`their -- their manufacturing.
` Q. Okay. And your role with Alcoa?
` A. With Alcoa, it was -- it was some of
`that. But it was also in conjunction with an
`academic program that was in place at MIT at the
`time, where I supervised a student who worked at the
`Alcoa facility, where we worked on some problems.
`But, also, based on that, he wrote a master's thesis
`that came out of that -- that effort.
` Q. But neither involved a design of
`pneumatic-conveying equipment, correct?
` A. I think that's right.
` Q. Okay. Any other publications that
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 26
`
`relate to pneumatic-conveying equipment?
` A. Well, there -- there are -- there is
`a -- a set of papers here, all associated with the
`compaction and constituent behavior of powder
`metals.
` Q. Okay.
` A. But if you exclude those, the answer is
`no.
` Q. Okay. Now, let's talk for a moment
`about this compaction. What is there about
`compaction that might relate to the positive
`pneumatic flow of materials?
` MR. ROSE: Objection to form.
` THE WITNESS: I'm sorry. Can I have
` that question again, please.
` MR. CARLSON: Would you read it back,
` please.
` (The following question was read back:
` Q: Now, let's talk for a moment about
` this compaction. What is there about
` compaction that might relate to the positive
` pneumatic flow of materials?)
` THE WITNESS: So, once again, that's a
` big question. I'll -- I'll just provide an
` example, which is: In pneumatic conveying, if
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`JANE ROSE REPORTING
`1-800-825-3341
`
`National Court-Reporting Coverage
`janerose@janerosereporting.com
`
`
`
`US Patent and Trademark Office
`Dynamic Air v. M-I Drilling
`
`FINAL - November 9, 2016
`Stuart Brown, Ph.D. - Vol. 1
`
`Page 27
` the density of powder particles gets too high,
` you can get two phenomenon -- two phenomena.
` Excuse me. Two phenomenons. So much for my
` English degree. The -- one is, you can get
` bridging, which is a process by which the
` particles by their density interlock. They
` don't -- they don't move anymore. They
` interfere with their -- the motion.
` And then if -- if, under -- under
` positive pressure, the air can't move through
` that -- that compacted mass sufficiently, if
` the permeability isn't sufficient, then you --
` you get a pressure differential across that
`
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