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` Darrin Young, Ph.D. - 2/17/17
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________________________________
` FITBIT, INC.,
` Petitioner,
`
` v.
`
` ALIPHCOM, INC., D/B/A JAWBONE
` Patent Owner
`
` Case IPR2016-00607
` Patent 8,529,811 BS
`________________________________________________________
`
` DEPOSITION OF DARRIN YOUNG, PH.D.
`
` February 17, 2017 * 9:06 a.m.
`
` Location: Holland & Hart, LLP
` 222 South Main Street, Suite 2200
` Salt Lake City, Utah
`
`Reporter: Heidi Hunter, RPR, CCR
`JOB NO. 119715
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`FITBIT EXHIBIT 1029
`Fitbit v. Aliphcom
`IPR2016-00607
`
`

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` Darrin Young, Ph.D. - 2/17/17
` A P P E A R A N C E S
`
`FOR THE PETITIONER FITBIT:
` Michael Hendershot
` PAUL HASTINGS
` Attorneys at Law
` 1117 South California Avenue
` Palo Alto, CA 94304
`
`FOR THE PATENT OWNER ALIPHCOM, INC., D/B/A/JAWBONE:
` Michael Guo
` WILSON SONSINI GOODRICH & ROSATI
` Attorneys at Law
` One Market Plaza
` Spear Tower
` San Francisco, CA 94105
`
`ALSO PRESENT:
` (None)
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` Darrin Young, Ph.D. - 2/17/17
` I N D E X
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`Page 3
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`DARRIN YOUNG, PH.D. PAGE
`
` Examination by Mr. Hendershot 4
`
` E X H I B I T S
`NO. DESCRIPTION
`
`FITBIT 1001 US Patent No. 8,529,811 to
` Drysdale et al
`FITBIT 1003 US Patent Application Pub.
` No. 2006/0264756 to Lo et al
`
`ALIPHCOM 2002 Darrin Young Curriculum Vitae
`
`Paper 14
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`ALIPHCOM 2001 Darrin Young Declaration
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` Darrin Young, Ph.D. - 2/17/17
` P R O C E E D I N G S
`
`Page 4
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` (ALL EXHIBITS PREMARKED.)
` * * *
` DARRIN YOUNG, PH.D.,
`called as a witness, being first duly sworn, was
`examined and testified as follows:
` EXAMINATION
`BY MR. HENDERSHOT:
` Q Good morning.
` A Good morning.
` Q I'm Mike Hendershot. I'm counsel for Fitbit.
`Can you do me a favor and state your name for the
`record.
` A Darrin Young.
` MR. GUO: And before we get too far, let me
`enter an appearance.
` MR. HENDERSHOT: Certainly. Sorry.
` MR. GUO: Michael Guo of Wilson, Sonsini,
`Goodrich & Rosati for patent owner Aliphcom, Inc., d/b/a
`Jawbone.
` Please. Sorry.
` MR. HENDERSHOT: And Michael Hendershot of
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` Darrin Young, Ph.D. - 2/17/17
`Paul Hastings, LLP, for Petitioner Fitbit.
` Q So, Dr. Young, you understand you're under
`oath today?
` A Yes, I understand.
` Q And the oath you take obligates you to tell
`the truth in response to my questions. Do you
`understand that?
` A Yes.
` Q Sitting here today is there anything that
`would prevent you from understanding my questions?
` A Nothing particular.
` Q Not taking any medication or anything like
`that?
` A No, I have not.
` Q Have you had your deposition taken before?
` A I had it once.
` Q So I will walk through some of the ground
`rules, and feel free to stop me or ask me questions if
`you don't understand. I'll be asking questions. You'll
`hopefully be providing answers.
` We have a court reporter here who will be
`taking things down. So I ask that you do two things and
`I'll endeavor to do the same. Provide clear, audible
`answers. We often nod in conversation, but the
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` Darrin Young, Ph.D. - 2/17/17
`transcript can't pick that up. And we do our best. It
`happens, but we do our best to avoid talking over one
`another or talking at the same time because it makes if
`difficult for the court reporter to take things down.
` Do you understand that?
` A Yes, I understand.
` Q You said were deposed once before; is that
`correct?
` A Yes.
` Q Can you describe the case in connection with
`which you were deposed?
` A It was a case between a patent -- for patent
`infringement lawsuit between a U.S. company and another
`company based in Australia.
` Q Have you ever testified at trial or any other
`live proceeding outside of a deposition?
` A Yes, I have.
` Q Was it also in that patent case?
` A Yes, it was.
` Q And I don't want you to reveal any potentially
`confidential information from that case, but can you
`describe generally what technology was at issue in that
`case?
` A It was about a cochlear prosthesis, a cochlear
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` Darrin Young, Ph.D. - 2/17/17
`implant technology.
` Q Had you worked with cochlear implant
`technology prior to that case?
` A What do you mean by "have I worked with
`cochlear implant technology"?
` Q Did any of your research prior to that case
`involve cochlear implant technology?
` A Yes, I have.
` Q In that case you were testifying on -- strike
`that.
` I assume you're offering expert testimony in
`that case involving the cochlear implant technology; is
`that correct?
` A That's correct.
` Q Were you an expert on behalf of the patent
`holder or the accused infringer?
` A Patent holder.
` Q In connection with your work on this petition
`between -- filed by Fitbit, are you being compensated
`for your time?
` A Yes, I have.
` Q At what rate?
` A $450 per hour.
` Q Is that your usual rate?
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` Darrin Young, Ph.D. - 2/17/17
` A That's right.
` Q Did you do anything to prepare for today's
`deposition?
` A Yes, I did something to prepare.
` Q Who did you meet with -- strike that.
` Did you meet with anyone to prepare for
`today's deposition?
` A I met with counsel.
` Q Did you meet with any nonattorneys in
`preparation for the deposition?
` A No, I did not.
` Q And how many times did you meet with counsel?
` A I met once.
` Q When was that?
` A Yesterday.
` Q And approximately how long did you guys meet
`to prepare for today's deposition?
` A We met about three -- three hours.
` Q And outside of meeting with counsel for about
`three hours yesterday, did you do anything else to
`prepare for today's deposition?
` A Yes, I did.
` Q What was that?
` A I read the documents.
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` Darrin Young, Ph.D. - 2/17/17
` Q About how long did you spend reading the
`documents?
` A Five, six hours.
` Q Do you know how many hours to date in total
`you billed to this case for this petition?
` A About somewhere between 30 to 40 hours.
` Q And you prepared a declaration in connection
`with this -- strike that.
` You understand that the patent owner has
`submitted a declaration from you in connection with this
`petition; is that correct?
` A That's correct.
` Q And the declaration you submitted in this --
`strike that.
` Your declaration in connection with this
`petition, did that contain all the opinions you've
`developed and intend to offer in connection with this
`petition?
` MR. GUO: Objection. Form.
` THE WITNESS: Could you repeat the question
`again.
` Q In preparing your declaration, did you set
`forth in that declaration all of the opinions you intend
`to offer?
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` Darrin Young, Ph.D. - 2/17/17
` A I offered my opinions with respect to the
`issues in my declaration.
` Q Okay. And all of your opinions in connection
`with this are written in your declaration; is that
`correct?
` MR. GUO: Objection; form.
` THE WITNESS: I wouldn't say all. It was all
`the issues that I was presenting. I provided my
`opinions.
` Q Okay. So on the issue you were presented and
`asked to provide an opinion on, all of your opinions
`with respect to those issues are written in your
`declaration; is that correct?
` A I would say so.
` Q And with respect to those opinions that are
`written in your declaration, does your declaration cite
`to all of the support you relied upon to form those
`opinions?
` A That's correct.
` Q Dr. Young, I'm going to hand you what's been
`marked in this proceeding as 2002. I believe it's your
`curriculum vitae. Take a minute to review it.
` Dr. Young, is what's been marked as
`Exhibit 2002 in front of you your CV?
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` Darrin Young, Ph.D. - 2/17/17
` A That's correct.
` Q Okay. Would you do me a favor and describe
`your educational background following high school.
` A I had a bachelor degree from electrical
`engineering and computer science from the University of
`California, Berkeley. And I had a master and the Ph.D.
`from the same field from UC Berkeley.
` Q What year did you obtain your Ph.D.?
` A 1999.
` Q And what did you do professionally after you
`obtained your Ph.D. in 1999? What was your next job?
` A My next job was assistant professor at the
`Case Western Reserve University.
` Q How long were you an assistant professor at
`Case Western?
` A I taught there for 10 years.
` Q You may have taught a colleague of mine
`actually, come to think of it.
` So that take -- so after -- after those 10
`years of being an assistant professor at Case Western,
`what was your next role?
` A I moved to University of Utah.
` Q Are you also a professor at the University of
`Utah?
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` Darrin Young, Ph.D. - 2/17/17
` A That's correct.
` Q And what do you teach at the University of
`Utah?
` A Electrical and computer engineering.
` Q And do you teach both undergraduate and
`graduate students or just one or the other?
` A I teach both.
` Q And you're currently a professor at the
`University of Utah?
` A That's correct.
` Q Did any of your work as a student in
`connection with either your bachelor's, master's, or
`Ph.D. involve the study of injection molding technology?
` MR. GUO: Objection; form.
` THE WITNESS: Well, my research was in
`microfabrication, you know, making semiconductor
`devices, and in order to task the device, I need to
`package the device. And for the package, we outsourced
`to external companies who make the package for us.
` Q What sort of packaging was -- strike that.
` For the packaging you just described that was
`outsourced in connection with the microelectronic
`devices, do you know what sort of packaging was applied
`to those?
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` Darrin Young, Ph.D. - 2/17/17
` A It was like ceramic packaging.
` Q Can you be more specific?
` A It's a typical standard ceramic package used
`to encapsulate sensors and integrate the circuit chips.
` Q Do you know how that ceramic packaging was
`applied to the microelectronic devices?
` A The microelectronic would be packaged inside
`the ceramic package as a protection as a way easier for
`users to handle it.
` Q Do you know how that ceramic package was
`applied to it, the application process?
` MR. GUO: Objection; form.
` Q Strike that. Do you understand -- strike
`that.
` Do you know what the application process was
`that was used to apply that ceramic package you just
`referenced?
` A I know.
` Q What was it?
` A It was a uniform package base, and you put the
`chip or your semiconductor device in the package. You
`do the wire bonding. Then you inject plastic, we call
`it encapsulation layer, over the package and basically
`there's a temperature, you know, cycling, cool it down.
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` Darrin Young, Ph.D. - 2/17/17
`Then you take it when you're done with it.
` Q And during that period -- strike that.
` And with respect to this ceramic packaging
`that was applied to microelectronic devices during your
`studies, were you ever present when that injection
`process went on?
` A No, I was not.
` Q In connection with your studies for either
`your bachelor's, master's, or Ph.D., did your studies
`involve wearable sensor technology?
` A It involved a sensor, but not at the time.
`We're now focusing on wearable.
` Q When you say "it involved a sensor," what sort
`of sensor did it involve?
` A Exometers, gyroscopes, precious inserts.
` Q So moving on to your work at Case Western, did
`any of your research at Case Western involve injection
`molding technology?
` A We used the injection molding technology as a
`fabrication step to make molds, and if the molds will be
`used by us to make sensors.
` Q So did you have an injection mold at your lab
`at Case Western that you used?
` A We outsourced.
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` Darrin Young, Ph.D. - 2/17/17
` Q And when you say -- correct me if I'm wrong or
`misstate any of this.
` As I understand it, at Case Western, during
`your time there, some of your research involved using a
`mold to make molds that were then used to make sensors?
` A Yes.
` Q What -- strike that.
` Can you just walk through me what that process
`involved, from your end personally?
` A For example, when we make sensors, if we want
`to make a -- like a 3D features, you know, typically you
`need to make a mold. Then you pour materials in the
`mold and then you pour that material out of the mold to
`form that shape. Then -- so that could be a particular
`layer, you know, used in your sensor.
` Then we go on with other, you know, related
`fabrication steps to finish making a sensor. Then we
`typically put the sensor on to a substrate and covered
`the sensor. So assembly we call it on the substrate to
`form a, you know, usable final module for people to
`test.
` Q And in that process that you described, would
`you or other people you researched with at Case Western
`decide what material would be used for a mold?
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` Darrin Young, Ph.D. - 2/17/17
` A Yes. I, you know, was in the process of
`deciding certain material for making the mold or making
`the sensor.
` Q In terms of the design of the 3-dimensional
`feature you were discussing, was that you or your
`researchers did at Case Western, or was that done by the
`party you outsourced it?
` A We did the design, a sym fabrication process.
`We just didn't do it, you know, in the university. We
`outsourced to external foundries to do the job.
` Q Did any of your research at Case Western
`involve wearable sensor technology?
` A It was mainly implantable at that time.
` Q And then in your work as Berkeley has any of
`your research involved injection molding technology?
` A We used injection molding technology, as I
`said earlier, fabrication step to make -- you know, to
`make the package to cover or encapsulate integrated
`circuits in the sensors.
` Q When you're covering integrated circuits or
`sensors like that, is that an entire -- strike that.
` What application are those integrated circuits
`and sensors you described used?
` A They used it for sensing applications. They
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` Darrin Young, Ph.D. - 2/17/17
`used it for communication applications.
` Q Would you explain to me what you mean by
`"sensing applications" on that answer?
` A For example, if you make an exometer, that
`detects vibration acceleration, and the exometer, you
`know, can be placed in vehicles or airplanes that
`detects that acceleration.
` Q I believe you said there was communication
`applications as well.
` A Yes.
` Q Could you explain what you meant by that?
` A Well, for example, we build integrated
`circuits as -- like a high-frequency transmitter to
`transmit signal -- like wireless communication. When
`you transmit a signal from one side to the other, you
`need to have some, you know, transmittal
`modulation/demodulation circuits.
` Q Did any of the projects you described -- I'm
`going to take a step back in time and ask the same
`question for each phase.
` So in your work at -- in connection with your
`studies at Berkeley, and for either your bachelor's,
`your master's, or your Ph.D., did any of the projects
`you discussed that involved injection molding involve
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`applying more than one molding layer to the device?
` MR. GUO: Objection; form.
` THE WITNESS: It certainly involves applying
`multiple layers, but different layers may be carried out
`or done differently. Some of them may be injection
`molding. Some may be not using injection molding
`process.
` Q Fast track this. Did any -- did any of your
`work -- I'm going to ask a long question but try to save
`us some time doing it.
` A Sure. Sure.
` Q Did any of the work or projects that you've
`referenced, either in your studies at Berkeley, your
`work at Case Western, or your work as a professor at
`Berkeley -- sorry. Strike that. Utah. So let me ask
`the question again.
` Did any of the projects you've described that
`involved injection molding from your studies at
`Berkeley, your work as a professor at Case Western, or
`your work as a professor at the University of Utah --
`strike that.
` It's actually -- you've got a good objection
`on that. I haven't got to Utah yet, have I?
` MR. HENDERSHOT: Have I asked him about
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`research, his research about Utah?
` MR. GUO: It's up to you.
` Q Has any of your work at the University of
`Utah -- strike that. I can scroll back.
` Has any of your research at the University of
`Utah involved injection molding technology?
` A Yes.
` Q Could you describe what portions or
`projects -- strike that.
` Could you describe what aspects of your
`research at the University of Utah involve injection
`molding technology?
` A Okay. So when we build sensors, for example,
`you know, flexible sensors, we -- we need to make a
`mold. And the mold, again, is designed by us and made
`or manufactured by external companies. And injection
`molding process often were used to make those molds.
` Q Has any of your research at the University of
`Utah involved wearable sensor technology?
` A Yes.
` Q Could you describe what aspects of your
`research at the University of Utah involved wearable
`sensor technology?
` A I've been working on a number of projects, you
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` Darrin Young, Ph.D. - 2/17/17
`know, involving wearable sensor technology. One of them
`is a -- you know, called a wearable pressure pad, go
`inside the shoe. And actually I started that project at
`Case Western. I moved it here, so the project moved to
`here with me. You know, that was used to provide
`personal navigation tracking.
` Okay. And other project is based on building
`flexible patch that can be, you know, attached to the
`surface, you know, human body skin to detect
`physiological signals. For example, your heart rate,
`blood pressure waveform.
` Q So for the project you described that involved
`a pressure sensor that's in a shoe --
` A Okay.
` Q -- you said that started at Case Western; is
`that correct?
` A Yes.
` Q Roughly when would you have started that
`research? What year?
` A 2007, 2009 -- no. Sorry. 2007, 2008.
` Q When did you start the work on the flexible
`patch research that you described?
` A That start about 2000 -- around 2012 or so.
` Q Now I'll try to fast track things.
`
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` Darrin Young, Ph.D. - 2/17/17
` Has any of your research -- either in
`connection with your work as a student at Berkeley, as a
`professor at Case Western, or as a professor at
`University of Utah -- involved the application of one
`molding that is then encapsulated by a second molding?
` MR. GUO: Objection; form.
` THE WITNESS: You know, my work involved using
`the molds to build sensors. And in order to make the
`molds, you know, you need to use different molding
`technique to make the mold. And that process involved
`multiple steps or different steps. Some can be
`injection molding; some may not be injection molding.
` Q Has any of your research as either a student
`at Berkeley, a professor at Case Western, or professor
`at the University of Utah involved the application of
`one mold to a sensor and then another mold on top of
`that that encapsulates it?
` MR. GUO: Objection; form.
` THE WITNESS: It involves sensors -- it
`involves like a protection layer, a molding layer on top
`of a sensor. Sometimes it also involves another --
`another coating, you know, like a -- it's a coating that
`coats all around it, using like a vapor deposition
`method. A very thin layer coating.
`
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` Darrin Young, Ph.D. - 2/17/17
` Q Has any of your work as either a student at
`Berkeley, a professor at Case Western, or a professor at
`the University of Utah involved the application of a
`molding to a sensor via an injection molding process and
`then the application of a second molding that
`encapsulates that first molding via an injection molding
`process?
` MR. GUO: Objection; form.
` THE WITNESS: We didn't use the injection
`process to provide that coverage. You know, we used,
`for example, sort of as a research prototype, we used --
`for example, we manually applied the protection layer on
`top of the sensor to protect the sensor. Then for a
`like hermetically sealed or water-resistant protection
`layer, we can't do it by hand. We have to go to using a
`machine to do that coating.
` MR. HENDERSHOT: Can you read my question back
`please?
` (The last question was read back.)
` Q Did you understand that question?
` A It's a very long question.
` Q Have you ever in your life -- we will
`eliminate the first part.
` Have you ever been involved in a project that
`
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` Darrin Young, Ph.D. - 2/17/17
`involved applying successive moldings to a device where
`both moldings are applied by an injection molding
`process?
` MR. GUO: Objection; form.
` THE WITNESS: When we make the molds to make
`the sensor, there will be multiple, you know, steps to
`make the mold. Some of them will be or can be injection
`molding. And once we use the mold to make the sensor,
`then we use a different techniques to passivate the
`sensor or cover the sensor.
` I'm not sure if I, you know, answered your
`questions.
` Q When you say "different techniques to
`passivate the sensor," are any of those -- strike that,
`do any of those involve injection molding?
` A For example, the electronic chip that we use,
`that we design and fabricate, our package is using, you
`know, the injection molding packaging technique to cover
`that chip. That is a standard -- as I mentioned
`earlier, like a ceramic type of packaging to package
`semiconductor device.
` Q At some point in your research from your time
`at Berkeley through your time at Utah, have you worked
`on a project -- strike that.
`
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` Darrin Young, Ph.D. - 2/17/17
` Have you ever designed an item that required
`the application of a molding that is applied via an
`injection molding technique?
` A Could you repeat the question?
` MR. HENDERSHOT: Can you read that back?
` (Record read.)
` THE WITNESS: I designed integrated circuit
`chip that needs to be packaged by a standard packaging,
`for example, ceramic package that does need an injection
`molding technique to package that chip.
` Q Other than that example, can you think of any
`others?
` A I designed molds that will be used to make the
`sensor. And that mold will be manufactured by using
`injection molding techniques.
` Q Any others?
` A Not that I can think of now.
` Q In your work either as a student at Berkeley
`or a professor at Case Western or Utah, have you ever
`designed an item that required the application of more
`than one coating that is applied by injection molding?
` A I have designed integrated circuit chips that
`needs to be packaged by a standard, you know, package.
`And in that package process there will be multiple -- as
`
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` Darrin Young, Ph.D. - 2/17/17
`protection layers needs to be provided. And some of
`those layers will be formed by using injection molding
`techniques.
` Q In any of those examples were multiple of
`those layers applied by using injection molding
`techniques?
` MR. GUO: Objection; form.
` THE WITNESS: Typically you need at least two
`layers to finish the encapsulation.
` Q When you say "two layers," are both of those
`layers applied by injection molding techniques, or are
`some applied by some different technique?
` A Depends on -- depends on the process that you
`pick. Some process may require a different technique
`than injection molding. Some process may use a standard
`injection molding technique to provide encapsulation.
` Q List for me every project you have worked on
`in your career that you can recall where an item had one
`layer or coating applied to it via injection molding and
`then another layer applied to it via injection molding
`on top of it?
` MR. GUO: Objection; form.
` THE WITNESS: For example, when I designed the
`integrated circuit chip, that chip needs to be packaged.
`
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` Darrin Young, Ph.D. - 2/17/17
`And that package is formed by injection molding, and
`that package may require multiple layers coverage to
`cover the sensor's surface.
` Q When you say "multiple layers" in that answer,
`are you referring to multiple layers applied by
`injection molding?
` A I think at least the top layer is done by
`injection molding.
` Q Can you recall any time in your career either
`as a student or professor where you designed an item
`that included one coating that is applied by an
`injection molding technique followed by a second coating
`that is applied by an injection molding technique?
` MR. GUO: Objection; form.
` THE WITNESS: I've looked into details about
`the specific package that I used at that time to make
`sure whether there are multiple injection moldings used
`to form the encapsulation.
` Q Without going back to look at that, do you
`remember an example of any such circumstance today?
` A To give you the correct answer, I need to look
`into it to make sure. I don't want to say wrong things
`to you.
` Q Can you any of any other example outside of
`
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` Darrin Young, Ph.D. - 2/17/17
`that -- strike that.
` With respect to that packaging example that
`you've discussed -- strike that too. Third time's a
`charm.
` The packaging of an integrated circuit and
`microelectronic device that you've discussed as the
`example of your work with injection molding, that
`packaging was used for what purpose?
` MR. GUO: Objection; form.
` THE WITNESS: Packaging used for handling
`purpose.
` Q When you send it off for testing?
` A Even when I -- when I touch it, test it by
`myself.
` Q Okay. Would that packaging remain on the
`device after the testing?
` A The package -- the package stays there because
`your -- your semiconductor device is already packaged
`inside. So it stays there.
` Q So it's not a temporary packaging that's used
`for shipping, for example, like many people use in the
`semiconductor industry; it's permanent packaging?
` MR. GUO: Objection.
` THE WITNESS: I'm not sure I understand your
`
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` Darrin Young, Ph.D. - 2/17/17
`question about "used for shipping."
` Q After the packaging was applied to the device
`as you've been discussing, was it ever removed?
` A Typically we don't remove it, but there are
`few times where things don't work right. We trying to
`remove, for example, the very top cap underneath
`microscope to look at to see if there's any breaking of
`bond wires or if there's any damage, for example, you
`know, you pushing too much current into the chip, you
`may see a blocked out somewhere on the surface, just for
`us to study the failure mechanism.
` Q At either -- strike that.
` Have you ever taught a course that involved --
`strike that.
` Have you ever instructed students on injection
`molding technology?
` A No, I have not taught them how to use
`injection molding technology because it's a standard
`process typically.
` Q Do other professors to your knowledge within
`the electrical engineering or computer engineering
`department teach injection molding technology as part of
`their courses?
` MR. GUO: Objection; relevance.
`
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