1
`
`Exhibit 2077
`Bradium Technologies LLC - patent owner
`Microsoft Corporation - petitioner
`IPR2016-00449
`
`

`

`2:10-cv—10578-PDB—DRG DOC # 170-7 Filed 12/21/1.2 Pg 2 of 11?
`
`Pg ID 12200
`
`CD‘-JChU'|II>-UJl\J}-'
`
`IN THE UNITED STATE DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF MICHIGAN
`
`SOUTHERN DIVISION
`
`VISTEON GLOBAL TECHNOLOGIES INC.,)
`
`and VISTEON TECHNOLOGIES, LLC,
`
`)
`
`Plaintiffs,
`
`V.
`
`GARMIN INTERNATIONAL,
`
`INC.,
`
`2:l0—CV—l0578—PDB—MAR
`
`Defendant.
`
`VIDEOTAPED DEPOSITION OF WILLIAM RYAN MICHALSON,
`
`taken on behalf of Plaintiffs, at the
`
`law offices OF Erise IP, 6201 College
`
`Boulevard, Suite 300, Overland Park, Kansas,
`
`beginning at 8:37 a.m. and ending at
`
`4:10 p.m., on November 9, 2012, before me,
`
`NAOLA C. VAUGHN, RPR, CRR, MO CCR NO. 1052.
`
`2
`
`

`

`2:10-CV-10578-PDB-DRG DOC # 170-7 Filed 12/21/12 Pg 3 of 117
`
`Pg [D 12201
`
`I N D E X
`WITNESS: WILLIAM RYAN MICHALSON
`
`Examination by Mr. Malik
`
`NUMBER
`
`EXHIBITS
`DESCRIPTION
`
`Exhibit 1 — Expert Report of William Michelson
`Exhibit 2 - Exhibits to Michelson
`Exhibit 3 - 11/5/12 letter to Jitendra Malik
`
`from Jason Mudd identifying 102/103
`prior art invalidity positions
`Exhibit 4 - Special Master's Clains Construction
`Remrt to the Honorable Paul Borma.n
`Exhibit 5 - GarInin's Opening Harkman Brief
`Exhibit 6 - Email string re: Claim Construction
`Briefs
`
`Exhibit 7 - Plaintiff's Final Infringelnent
`Contentions
`Exhibit 8 - Research in Vehicle Information
`
`Systems at General Motors
`GAR]-N—E|2—00244l5 — 24419
`
`Exhibit 9 - Order to Modify The Fourth
`Amended Joint Rule 26(f) Report
`Exhibit 10 - AutoRoute Plus Reference Hanual
`GAR}-N—02-OUUDSIJEI - 5160
`
`136
`
`139
`
`NUMBER
`
`EXHIBITS (Continued)
`DESCRIPTION
`
`Exhibit 11 - US Patent 5,220,507 (Kirson)
`Exhibit 12 - Us Patent 5,323,321 (Smith)
`Exhibit 13 — us Patent 5,243,528 (Lefebvre)
`Exhibit 14 — Integrating Business Listings
`with Digital Maps for Use in
`Vehicles
`GARHV-02-00016505 - 16511
`
`
`u14=-.|..aru|—-o\ocn-.Jo-\Ln-1:-L-:r~.:I—-oLaao~—Ja\Ln»a=-.Lnrun—-U145laahJb—I$\.Dfl3~_ll7\U1p¢h-LnJhJI—I@\DDD-—.lO\Lnnb-Lut~J)—-
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`
`
`APPEARANCES OF COUNSEL
`For Plaintiffs:
`
`ALSTON E BIRD, LLP
`Bank of America Plaza
`
`101 South Tyron Street
`Suite 4000
`
`23280-4000
`Charlotte, North Carolina
`(704)444-1000 - phone,
`(704)444-1595 - fax
`rick.mcderInott9a1ston.com
`
`jason.fridayEa1ston.com
`jitty.u:alik@a1ston.com
`BY:
`JASON A. FRIDAY
`and
`BY: RICK I-iCDERMO'1'I'
`and
`JITENDRA "JITI'Y" MALIK
`
`BY:
`
`For Defendant:
`
`ERISE IP, P.A.
`6201 College Boulevard
`Suite 300
`
`Overland Park, Kansas
`(913)777-5600 - phone,
`eric.buresh@eriseIP.com
`
`paul.hart@eri5eIP.com
`BY:
`ERIC A. BURESH
`and
`PAUL R. HART
`
`BY:
`
`65211
`(913)7T:‘~5601 — fax
`
`Also Present: David Ayers, Garmin
`Kathleen Fitterling
`Jim Ross, videographer
`
`&)I.‘JN1’|\|hJ3\J|—‘|—'|P-‘I-—-‘|—l|—‘|—‘I—‘l—'I-H'J1IU>LAlI\JI—|ZlOII-uJO\lJ1Ih-LnJ3\Jl—‘E\D1*—JG\lJ'|o|=-Ln)I\JI—|
`
`1 2 3 4 5 6 7 8 9
`
`10'
`11
`12
`13
`14
`15
`16
`17
`1B
`19
`20
`21
`22
`23
`24
`25
`
`3
`
`

`

`2:10-CV—10578—PDB-DRG DOC # 170-7 Filed 12/21/12 Pg 4 of 11?
`
`Pg ID 12202
`
`FL
`
`Page 6
`{Exhibits 1 and 2 marked.)
`THE VIDEOGRAPEER: This is the
`
`1 in the deposition of
`beginning of the tape No.
`William Michalson in the matter of Visteon v.
`Garmin. Case Number is 2:10—CV—1l}58—PDB—MAR.
`
`Today's date is November the 9th, 2012.
`is 8:37 a.m.
`_
`
`The time
`
`I'm the
`My name is Jim Ross.
`videographer. The court reporter is Naola Vaughn.
`We're with Huseby Court Reporting.
`Counsel, will you please introduce
`yourselves, after which the court reporter will
`swear the witness.
`
`MR. MALIK: Good morning. This is
`Jitendra Malik of Alston & Byrd representing
`Plaintiff, Visteon. With me is Jason Friday and
`Rick McDerrrott, also of Alston Bird. And also
`Dr. Anatole Lokshin.
`MR. BURESH: Eric Buresh of Erise IP
`on behalf of Garmin. With use is Kathleen
`
`Fitterling, also with Erise IP. And joining us is
`David Ayers,
`in-house counsel at Garmin.
`WILLIAM RYAN MIC]-IALSON,
`
`a witness, being first duly sworn, testified as
`follows:
`
`BY MR. MALIK:
`
`EXAMINATION
`
`Good morning, Dr. Michelson.
`Q.
`Good morning.
`A.
`For the record would you please state
`Q.
`your full name and address.
`A.
`William Ryan Michalson, and I live on
`Linden Street in Douglas, Massachusetts.
`Q.
`Okay. Let me hand you what I have
`marked as Michelson Exhibit 1 and Exhibit 2.
`
`Dr. Michalson, do you recognize
`Michalson Exhibit 1 and Exhibit 2?
`
`Exhibit 1 is my mcpert report and
`A.
`Exhibit 2 are exhibits to that report.
`Q.
`and if you turn to the last page of
`Exhibit 1, can you please confirm that that is
`your signature?
`A.
`Yes, it is.
`(Exhibit 3 marked.)
`BY MR. MALIK: Okay. And let me also
`Q.
`go ahead and hand you 1-Lichalson Exhibit 3.
`Have you seen Michalson Exhibit 3
`
`before?
`A.
`
`Yes.
`
`Q.
`
`Okay.
`
`It's mostly for reference
`
`Page 8
`_
`_
`Just it will make the conversation a
`purposes.
`little easier.
`
`Okay. And let me also hand you what
`is previously marked as Fosmoen Exhibit 10, which
`is the 375 patent. Have you seen the 375 patent
`before?
`A.
`
`Yes.
`
`let me hand you Peterman
`Okay.
`Q.
`Exhibit 4, previously marked, which is the 408
`patent.
`
`Have you seen the 408 patent before?
`Yes.
`
`A.
`
`Let me also hand you Fosmoen
`Q.
`Exhibit 8, the 892 patent.
`Have you seen the 392 patent before?
`Yes, I have.
`A.
`Let me also hand you Peterman
`Q.
`Exhibit 3, which is the 060 patent.
`Have you seen Peterman Exhibit 3
`
`before?
`A.
`
`Yes.
`
`Okay. Michalson Exhibit 1 opines on
`Q.
`four patents. Are they the four patents that I
`just handed you?
`A.
`Yes.
`
`Page 9
`
`Dkay. And you understand that
`Q.
`Michalson Exhibit 1 was supposed to be a complete
`statement of your opinions?
`A.
`That's correct.
`
`Okay. Can you please state your
`Q.
`educational background starting from college?
`A.
`Yes.
`I got my bachelor's degree from
`Syracuse University --
`Q.
`Okay.
`I got
`A.
`-— in, I believe it was, 1981.
`my master -- and that bachelor's degree was in
`electrical engineering.
`I got a master's degree in electrical
`engineering from Worcester Polytechnic Institute
`in Worcester, Massachusetts.
`I think that was
`'35. And then a PhD in electrical engineering
`also from Worcester Polytechnic Institute in 1989.
`Q.
`Okay.
`In your report you talk about
`your work with the Raytheon Company from 1931
`through 1991 on page 6.
`A.
`That's correct.
`
`While with Raytheon -- and it said
`Q.
`that on page 7 that you held several engineering
`positions at Raytheon Company.
`Can you describe to me what those
`
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`4
`
`

`

`2:10-CV-10578-PDB-DRG DOC # 170-7 Filed 12/21/12 Pg 5 of 11'?
`
`Pg ID 12203
`
`Page 10
`engineering positions were and the kind of work
`that you were involved with?
`A.
`Sure. Sure.
`I started working with
`the computer and displays laboratory. That
`computer displays laboratory was part of equipment
`division, and we did a lot of work for, really,
`all of the departments in -- within the domain of
`equipment division.
`So I did work with comrmmication
`
`I did work with navigation and tracking
`systems.
`systems, things like redesigns of Patriot missile
`system guidance computer, Trident missile system
`guidance computer, air traffic control systems,
`primarily for military applications, but also some
`of the computer and display systems for the
`inflight air traffic control, the major -- the
`hubs that interconnect major hubs.
`Computer design for some space—based
`missile defense systems for tracking and
`predicting points of impact for incoming ballistic
`missiles, and a variety of communication systems,
`Milstar satellite System, which was a tri—service
`communication system. Track 170 triple scatter
`radio. Did some work with that system. That's a
`terrestrial-based system that's used largely by
`
`Page 11
`
`the Army.
`Did you ever do any work with
`Q.
`developing any consumer GPS devices or were they
`all military applications?
`A.
`when we're dealing with the consumer
`GPS, I did a lot of work with consumer GPS
`systems. Not anything that was productized at the
`time, but I had built a differential GPS system
`for the Department of Forestry. Built a GPS—based
`collision avoidance system for Providence and
`Worcester Railroad.
`
`Did some in-vehicle navigation system
`work for Bose Corporation.
`So definitely a number of cozrmercial
`applications .
`Q.
`But anything directed to ordinary
`consumer kind of GPS device that I would buy at
`Best Buy?
`A.
`
`The Base work would have been directed
`
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`
`l\JU1
`
`_at an in-vehicle navigation system.
`Q.
`Okay. With regard to the Bose work,
`can you just expand on that a little bit? What
`were you asked to do with Bose, and was this with
`Raytheon?
`A.
`
`That was not with Raytheon. That was
`
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`
`Page 12
`
`subsequent to Raytheon.
`With the Bose system at that point in
`time, that was very early '90s, the writing was on
`the wall that vehicle navigation systems would
`start getting incorporated into automobiles.
`Bose had tremendous interest in
`
`building systems to integrate their sound system
`with vehicle navigation system.
`So for a couple
`of years I got financing from Bose to develop some
`prototypes of a system that is very similar to
`what we see today. We had the Navitech nap
`database. We would get GPS-based positions. We'd
`put the vehicle on the map. We'd, you know, do
`the turn-by-turn directions, and, you know, we
`were developing systems that were focused exactly
`on that sort of application.
`Q.
`At the time you weren't employed by
`Bose, were you?
`I was
`A.
`I was not employed by Bose.
`employed by Worcester Polytechnic Institute, but
`we had some graduate and undergraduate research
`that was working on those areas.
`Q.
`And they financed those areas?
`A.
`They financed some of my work in that
`area, yes.
`
`Page 13
`Okay. Was —— and you said the Bose
`Q.
`system was never commercialized, correct?
`A.
`I don't know what they ended up doing
`with it.
`I know that we worked with them for a
`
`couple of years. We had some prototype
`demonstrations, and Bose then took the results of
`
`our work, and I don't know where it might have
`ended up.
`It may have ended up in some other OEH
`equipment, or it may have ended up biasing other
`system requirements that they passed on to others.
`Q.
`with respect to your work in Bose
`during that two—year period -— and this was 1991,
`'92?
`
`Probably starting around late '91 on
`A.
`up to probably about
`'94,
`'95.
`Q.
`What percentage of your time was
`dedicated to working on the Bose project?
`A.
`Boy, difficult to answer.
`I would say
`probably the Bose project was probably about 10 or
`15 percent of my time.
`Q.
`Okay.
`A.
`I had other related projects through
`that time period that, you know, would have been
`consuming some of my time.
`I had a lot of -- at
`that point in time I had a lot of financing also
`
`5
`
`

`

`2:10-CV-10578-PDB—DRG DOC # 170-? Filed 12/21/12 Pg 6 of 11?
`
`Pg ID 12204
`
`Page 14
`from the Federal Aviation Administration for -— at
`
`that point, GPS was not yet qualified for use in
`what we called sole means navigation systems. And
`there was a process of trying to determine what
`the right kind of testing to do on GPS
`navigation —- GPS—hased navigation systems for
`commercial aircraft -- what the regulations should
`be.
`
`So we were in -- we, WPI, and my lab
`in particular, had a number of contracts with FAA
`in which we were involved with that standards
`
`process. We were involved with testing and
`evaluating algorithms and things of that nature.
`Q.
`Have you ever worked for a company
`that develops consumer PNDs like Garmin, Hagellon,
`TomTom'?
`A.
`
`I've been involved with some -- with a
`
`startup that was a -- it was not a commercially
`successful startup, but, you know, we were —- we
`were developing a PND~like product, and I had
`prototyped that PND—-like product.
`Q.
`All of the discussion that we've had
`so far has mostly been about your development
`projects from an engineering perspective.
`Have you ever worked directly with GPS
`
`Page 15
`
`consuners in a marketing role?
`A.
`In a marketing role, no.
`Q.
`Okay.
`On page 9 of your report, you
`provide your definition of a person of ordinary
`skill in the art.
`A.
`That's correct.
`
`Q.
`A.
`
`Do you meet that definition?
`Yes.
`
`Okay. Have you had a chance to review
`Q.
`the qualifications of Dr. Anatole Lokshin?
`A.
`It's been a while since I reviewed his
`But I have reviewed his CV.
`
`CV.
`
`As you sit here today, is there any ——
`Q.
`do you have any reason to doubt that Dr. Lokshin
`would not be a person of ordinary skill in the
`art?
`
`His CV suggests that he should be.
`A.
`Okay.
`Look at the exhibits to your
`Q.
`report, Exhibit 2 -— I believe it's probably
`buried under here. Let's turn to page 3 of 31,
`Exhibit A.
`
`Under Consulting Exwiences, Law
`Related, 1.4.1, let me know when you're there.
`A.
`Yeah.
`
`Q.
`
`I see that you've testified as an
`
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`Page 16
`expert in a number of cases over the past few
`years.
`
`A.
`
`Yes.
`
`I noticed that Ga.rmin
`Okay.
`Q.
`International happens to be —- well, happens to be
`named in a number of these cases.
`
`In your representation of Ga.rmin, were
`you always the validity expert or have you ever
`served as their infringement expert?
`A.
`Depending on the case, I have worked
`with Garmin on both —- on the validity side and
`the infringement side.
`Q.
`Okay. Let's start with in the cases
`where you were a consultant for Garmin on the --
`when Garmin was a defendant.
`
`In those cases did you offer an
`opinion on validity or infringement or both?
`A.
`It depends on the particular case.
`Sonetirres one or the other or both.
`
`In the instance when Garrnin was
`okay.
`Q.
`a defendant, did you offer -- ever offer an
`opinion in any expert report that the patents were
`"valid?
`
`No.
`
`Okay.
`
`In the instance where Garmin
`
`Page 1'7
`
`was a defendant and you were an infringement
`report, did you ever offer an opinion that the
`patents were infringed?
`A.
`No.
`
`In the instance where you are a
`Okay.
`Q.
`consultant for Garmin and Garmin was a plaintiff,
`did you ever offer an opinion that the patents
`were invalid? In other words, Garmin's patents
`were invalid?
`A.
`The case in which Ga.rmin was a —— was
`
`the plaintiff was a declaratory judgment case.
`it was not a Garmin patent that was at issue.
`Q.
`Okay.
`okay. And that's the only time
`that you've been a -— you've represented Garmin as
`a plaintiff?
`A.
`
`Correct.
`
`So
`
`Q.
`A.
`
`Okay. or consulted with?
`Yes. Consulted with.
`
`Now, by my count, I see that you
`Q.
`represent -— well, you consulted for Garmin eight
`times.
`It's one,
`two, three, four —— there may be
`more because sonetiiuwesthe ITC cases don't state
`Garmin, but
`.
`.
`.
`A.
`I count seven total.
`
`Q.
`
`okay.
`
`I'll accept seven.
`
`6
`
`

`

`2:10-CV-105.78-PDB-DRG DOC # 170-7 Filed 12/21/12 Pg of 117
`
`Pg ID 12205
`
`Page 18
`Over the years, how much money have
`you made consulting for Garmin?
`A.
`I haven't -- I haven't calculated it
`
`I think in the last case I was asked
`recently.
`that question, it was somewhere around $400,000.
`Q.
`Okay. What is your current salary?
`A.
`My current salary comes from both my
`consulting company and the university. Last year
`it was, I think, just a little bit shy of
`$600,000.
`How much does the university pay you?
`Q.
`It varies depending on what sponsored
`A.
`research I have, but currently it's around
`$125 ,00D.
`Q.
`consulting?
`A.
`
`And the rest comes from your
`
`Correct.
`
`And of your consulting, how much of
`Q.
`that portion is related to your law -- law—related
`consulting?
`I would say probably about 70 or 80 is
`A.
`law-related consulting.
`Q.
`Okay.
`In the cases where you —-
`obviously thHe's other cases on 3 of 31 through 7
`of 31.
`
`Page 19
`I'm not going to ask any specifics,
`but obviously you represent other folks other than
`Garmin, correct?
`A.
`Correct.
`
`In those cases, did you represent
`Q.
`those other folks as —— when those parties were
`defendants or plaintiffs or both?
`‘
`A.
`A little bit of both.
`
`In the cases where you
`okay.
`Q.
`represented those other folks,
`those other
`companies as a consultant and the company was a
`defendant, did you ever opine that the patents
`were valid?
`
`By the time they got to the point
`A.
`where -- you know, that we were litigating
`patents, the patents that were being litigated, I
`did not believe were valid.
`
`Q.
`
`In the cases where those other folks
`
`were plaintiffs and you were a validity expert,
`did you ever offer an opinion that the patents
`were invalid?
`
`I haven't provided an —- I've never
`A.
`provided an opinion on a patent that I -— well,
`how do I say this?
`If I think a patent is valid, I've
`
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`I
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`I
`never said it's invalid and vice versa.
`
`Page 20
`
`Do you currently have a
`Okay.
`Q.
`retainer with Ga.rmi.n?
`A.
`I'm retained for this case and for the
`other cases that are mentioned here.
`
`Q.
`Garmin?
`A.
`
`Do you have a standing retainer with
`
`No.
`
`Let's turn to Exhibit B on Hichalson
`Q.
`Exhibit 2. What is the purpose of Exhibit B in
`your opinion?
`MR. BDRESH:
`
`Objection, vague.
`Okay. Why did you
`
`BY MR. MALIK:
`Q.
`include Exhibit B?
`
`Exhibit B is a list of hopefully all
`A.
`of the materials that I reviewed in connection
`
`with this report.
`Q.
`Okay. Can you please confirm for me
`after reviewing Exhibit B that Exhibit B makes no
`reference to the Nuvi 3750?
`A.
`I don't see a reference here to the
`
`3750.
`
`Could you please confirm for me that
`Q.
`Exhibit B, in fact, makes no reference to any
`Garmin product that is accused in this litigation?
`
`Page 21
`
`A.
`Q.
`
`That appears to be correct.
`Okay.
`Thank you.
`
`‘Why don't we go back to Michelson
`Exhibit 1. "And let me direct your attention to
`page 10. At the -- on page 10 of the Section 0,
`Legal Standards, at the very end it says, last
`sentence, "Second,
`the construed claims are then
`compared to the prior art to determine whether the
`prior art anticipates or renders obvious the
`construed claims."
`
`Do you see that?
`No. Not yet.
`Oh.
`Oh, okay.
`Yeah.
`Yes.
`
`A.
`Q.
`A.
`Q.
`A.
`
`What did you mean by that statement?
`Q.
`What I mean by that is if there is a
`A.
`claim construction, which there is, that you need
`to do an analysis relative to that claim
`construction.
`
`Okay. And is that -- and in
`Q.
`performing your analysis, that's how you -- well,
`strike that.
`
`In rendering the opinion that is
`
`,_.,_.
`
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`7
`
`

`

`2:10-CV~l0578-F’DB—DRG DOC # l70~7 Filed 12/21/12 Pg 8 of 11?
`
`Pg ID 12206
`
`Page 22
`represented in Michalson Exhibit 1, you compared
`the prior art to the construed claims?
`A.
`I --
`
`Q.
`construed?
`A.
`
`In the event the claims were
`
`Yeah.
`
`In the event -- for those claim
`
`terms that we had constructions by the court for,
`I applied those constructions in interpreting the
`claim language.
`Q.
`Okay. And also for the purpose of
`determining whether the prior art anticipates or
`renders obvious the construed claims?
`A.
`That's correct.
`
`I know you provide your
`Okay.
`Q.
`understanding of anticipation under D.l. There it
`says,
`"A claim is anticipated for either prior art
`if each and eve
`limitation of the claim is
`disclosed in a gingle item of prior art."
`What do you mean by that?
`That for anticipation, all —— every
`A.
`element has to be present in a single piece of art
`or in a single system.
`Q.
`If
`element is missing, is the claim
`anticipated?
`A.
`
`If an element is missing, it would --
`
`Page 3
`
`it would not be anticipated.
`Q.
`Okay. Let's turn to your
`understanding of obviousness, which is described
`on pages 11, 12 and -- through 14, I believe.
`Do you understand that there's --
`wait. Have you ever heard the term "obviousness"
`and obviousness —- "obvious to try"?
`A.
`Yes.
`
`Do you have any understanding of the
`Q.
`difference between the two?
`
`Well, obvious to try would be
`A.
`something that one of skill in the art, based on
`their background, would reasonably —— would be --
`if for somebody -— for somebody of skill in the
`art, that it would be a -- the kind of thing that
`that person might have a reasonable expectation
`might work, and, therefore, it would be reasonable
`to try that combination.
`Q.
`And do you have any understanding how
`that is different from obviousness?
`
`I think that at least —— well, let me
`A.
`see if I cover that in more detail in my -- in my
`report here.
`Q.
`A.
`
`Please. Take your time.
`Yeah, I guess the -— my interpretation
`
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`Page 24
`of just general —— obviousness in general would be
`that, if you're going to try to develop a product,
`you're going to have some kind of specification
`for that product that you -- that you want to
`ultimately develop.
`And, you know, those things that are
`obvious are going to be those things that informed
`by your general knowledge of the problem domain
`and the art that's in that domain, kind of that
`universe of things that forms your toolbox for
`solving that problem; that, you know, if I'm —— if
`I need to build a corrputer system,
`then it's
`obvious that I would need a display and a monitor.
`You know, a display, some kind of remory storage,
`some kind of keyboard entry, things of that
`nature.
`
`I guess what I'm trying to understand
`Q.
`is in your report you talk about how certain of
`the asserted patents are obvious.
`A.
`Correct.
`
`What I'm trying to understand is are
`Q.
`you articulating an obvious rationale or an
`obvious to try rationale?
`A.
`I think we'd need to look at
`
`individual examples. And I would try to help you
`
`Page 25
`know where my head was coming from at that -— on
`those examples.
`Q.
`Okay. Let's look at page 14, your
`understanding of written description enablement
`and best mode.
`It's Section 4 on page 14.
`A.
`Yes.
`
`Just right off the hat, I reviewed
`Q.
`your report, and I couldn't see any invalidity
`position based on best mode.
`Is that correct?
`
`Is that consistent
`
`with your understanding?
`A.
`I would want to look through it.
`can't recall one right at the moment.
`Q.
`Okay. With respect to written
`description and enablement, do you understand that
`written description and enablement are two
`separate inquiries?
`A.
`Yes.
`
`I
`
`Q. What's your understanding of the
`difference between the two?
`
`A. Well, written description is more of a
`situation where does the —— does the patent
`demonstrate to one of skill in the art that the
`
`inventor had possession of the idea being
`patented, did they disclose it in such a way that
`
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