Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________________
` GENERAL ELECTRIC COMPANY
` Petitioners,
` vs.
` UNITED TECHNOLOGIES CORPORATION
` Patent Owner.
`______________________________________________________
` Case IPR2016-00952
`
` VIDEOTAPED DEPOSITION OF REZA ABHARI, Ph.D.
` REDWOOD SHORES, CALIFORNIA
` WEDNESDAY, JANUARY 4, 2017
`
`BY: ANDREA M. IGNACIO, CSR, RPR, CRR, CCRR, CLR ~
`CSR LICENSE NO. 9830
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2013.001
`
`GE v. UTC
`Trial IPR2016-00952
`
`

`

`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`2
`
`A P P E A R A N C E S:
`
` FOR THE PATENT OWNER:
` FINNEGAN, HENDERSON, FARABOW, GARRETT &
` DUNNER, LLP
` By: PATRICK J. COYNE, Esq.
` 901 New York Avenue, NW
` Washington, D.C. 20001-4413
` Phone: 202.408.4000
` patrick.coyne@finnegan.com
`
` FOR THE PETITIONER:
` WEIL, GOTSHALL & MANAGES LLP
` By: ANISH DESAI, Esq.
` CHRISTOPHER M. PEPE, Esq.
` 1300 Eye Street, N.W., Suite 900
` Washington, D.C. 20005
` Phone: 650.354.4154
` anish.desai@weil.com
`
` ALSO PRESENT: Janice V. Jabido, Pratt & Whitney
` Frank Quiarte, Videographer
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`3
`
` I N D E X
`WITNESS: Reza Abhari, Ph.D.
`
`EXAMINATION PAGE
`By Mr. Coyne 6
`By Mr. Desai 183
`
` E X H I B I T S
`EXHIBIT PAGE
`Exhibit GE-1001.001 U.S. Patent 9,121,412 5
` - 1001.006
`Exhibit GE-1003.001 Declaration of Reza 5
` Abhari, Ph.D. - 1003.071
`Exhibit GE-1005.001 1976 Spring Convention 5
` Seeds for Success in Civil
` Aircraft Design in the Next
` Two Decades - to 1005.023
`Exhibit GE-1011.001 Quiet Clean Short-Haul 5
` Experimental Engine (QCSEE)
` Final Report - to 1011.312
`Exhibit GE-1016.001 Follow-On Technology 5
` Requirement Study for
` Advanced Subsonic
` Transport - to 1016.058
`///
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`4
`
` E X H I B I T S (Continued.)
`
`EXHIBIT PAGE
`Exhibit UTC-2012.001 Parametric Cycle Analysis 29
` of Ideal Engines, pages
` 299 - 305
`
` ---oOo---
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`5
` REDWOOD SHORES, CALIFORNIA
`08:32
` WEDNESDAY, JANUARY 4, 2017
`08:34
` 9:15 A.M.
`
` (Exhibits GE-1001, GE-1003, GE-1005,
` GE-1011 & GE-1015 marked for
` identification.)
` THE VIDEOGRAPHER: All right.
`08:36
` Good morning, ladies and gentlemen. We're on
`09:15
`video record. The time is approximately 9:15 a.m.
`09:15
` I am Frank Quirarte from Henderson Legal
`09:15
`Services in Washington, D.C. The phone number is
`09:15
`(202) 220-4158.
`09:15
` This is a matter pending before the United
`09:15
`States Patent and Trademark Office. It's being --
`09:15
`before the Patent Trial and Appeals Board.
`09:15
` It's a case captioned General Electric
`09:15
`Company versus United Technologies Corporation. IPR
`09:15
`No. 2016-00952.
`09:16
` This is the beginning of Tape 1, Volume I, in
`09:16
`the deposition of Dr. Reza Abhari, on January 4th,
`09:16
`2017.
`09:16
` We're located at 201, Redwood Shores,
`09:16
`California.
`09:16
` At this time, will counsel and all present
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`6
`please identify yourselves for the record.
`09:16
` MR. COYNE: Patrick Coyne of Finnegan's
`09:16
`Washington, D.C., office, for Patent Owner, Bratton
`09:16
`Wood, United Technologies Corporation.
`09:16
` MS. JABIDO: Janice Jabido from Pratt &
`09:16
`Whitney.
`09:16
` MR. DESAI: Anish Desai from Weil Gotshal,
`09:16
`here on behalf of General Electric.
`09:16
` MR. PEPE: Chris Pepe with Weil Gotshal,
`09:16
`appearing for General Electric as well.
`09:16
` THE VIDEOGRAPHER: Madam Court Reporter, will
`09:16
`you please swear in the witness.
`
` REZA ABHARI, Ph.D.,
` having been sworn as a witness
` by the Certified Shorthand Reporter,
` testified as follows:
`
` EXAMINATION
`BY MR. COYNE:
` Q Good morning, Dr. Abhari.
`09:16
` A Good morning.
`09:16
` Q It's good to see you again.
`09:16
` A Nice seeing you.
`09:16
` Q Thank you for taking the time to come over.
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`7
`I know this is a long trip for you.
`09:17
` I want to do some of the preliminaries again,
`09:17
`even though we've done them before, because this is a
`09:17
`separate record.
`09:17
` A I understand.
`09:17
` Q In addition to the testimony you gave in
`09:17
`two prior IPRs in September, have you ever testified
`09:17
`in any other proceeding?
`09:17
` A No, I have not.
`09:17
` Q Okay. Have you given any other deposition
`09:17
`testimony in any other proceeding?
`09:17
` A No, I have not.
`09:17
` Q Okay. You understand that your trial
`09:17
`testimony in this particular proceeding was submitted
`09:17
`with your declaration that you submitted a couple of
`09:17
`months ago; correct?
`09:17
` A Correct.
`09:17
` Q Okay. And that this is an opportunity for
`09:17
`Pratt & Whitney to explore the basis for your
`09:17
`opinions, to -- to probe, to examine your opinions.
`09:17
`You understand that; don't you?
`09:17
` A I do.
`09:17
` Q Okay. Thank you.
`09:17
` You understand that you're required to
`09:17
`testify truthfully today; don't you?
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`8
` A I do.
`09:17
` Q Just as if the board members were present in
`09:17
`the room with us; correct?
`09:17
` A I do.
`09:17
` Q Okay. If we get into it today, let's try not
`09:17
`to over-speak. It makes it exquisitely difficult for
`09:17
`the court reporter to take down what everybody is
`09:18
`saying.
`09:18
` A I'll do my best, but maintaining the context.
`09:18
` Q And I will try as well.
`09:18
` If you don't hear any of my questions, please
`09:18
`don't try to guess at my meaning or try to figure out
`09:18
`what I said. Please just ask me, and I'll be happy to
`09:18
`try to rephrase it or repeat it for you; okay?
`09:18
` A I will be happy to.
`09:18
` Q Okay. If you don't understand any of my
`09:18
`questions, even if you heard it, please don't try to
`09:18
`guess at my meaning. Just ask, and I will try to
`09:18
`clarify it for you; okay?
`09:18
` A I will.
`09:18
` Q Thank you.
`09:18
` This is not an endurance contest. If you
`09:18
`need to take a break at some point, please let me
`09:18
`know, and we'll do that. I would just ask that you
`09:18
`not do it when there is a question pending; okay?
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`9
` A That will be fine.
`09:18
` Q Okay. You understand that you're required to
`09:18
`answer my questions today, unless counsel objects on
`09:18
`the grounds of attorney-client privilege; correct?
`09:18
` A Yes.
`09:18
` Q Okay. And will you try to do that?
`09:18
` A I will.
`09:18
` Q Okay. You'll have an opportunity to review
`09:18
`your testimony today after the court reporter has
`09:18
`prepared a transcript. It's not an invitation to
`09:19
`change it, but it is an opportunity to correct any
`09:19
`errors. You understand that; don't you?
`09:19
` A I do.
`09:19
` Q Okay. Is there any reason you would not be
`09:19
`able to answer my questions today truthfully?
`09:19
` Stress? Medications? Any other issues?
`09:19
` A No.
`09:19
` Q Okay. Thank you.
`09:19
` You -- when were you retained by Weil for
`09:19
`this particular IPR proceeding?
`09:19
` A I do not recall the exact date because, as I
`09:19
`mentioned to you during the last testimony, there were
`09:19
`a number of particular patents in question. And this
`09:19
`goes back almost two years from now. I don't remember
`09:19
`when this specific patent entered the discussion.
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`10
` Q Okay.
`09:19
` A It has been within the last two years.
`09:19
` Q Okay. Your testimony in this proceeding was
`09:19
`submitted -- well, you -- at least it's executed on
`09:19
`23 April 2016.
`09:19
` Does that help refresh your recollection when
`09:20
`you were retained for this particular proceeding?
`09:20
` A Well, as I mentioned, the exact retaining for
`09:20
`this proceeding was -- it's not in my memory, because
`09:20
`it was a suite of patents that we were discussing.
`09:20
` But, it is correct that almost a year ago I
`09:20
`was working on this, and it was filed about
`09:20
`nine months ago.
`09:20
` Q Okay. So --
`09:20
` A So in that time frame.
`09:20
` Q -- was it --
`09:20
` A I don't know the exact date. Was it a year
`09:20
`ago or -- somewhere between one to two years ago.
`09:20
` Q Okay. Well, here, let me hand you a copy of
`09:20
`your testimony -- your declaration in this proceeding.
`09:20
` THE REPORTER: Counsel, if you can put your
`09:20
`mic on, please. Thank you.
`09:20
` MR. COYNE: Okay. So it was about
`09:20
`nine months ago.
`09:20
` Q Do you recall -- it would have to have been
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`11
`before April 23; correct?
`09:20
` A Yes, true.
`09:20
` Q Okay.
`09:20
` A It was filed in 2015, so I don't know exactly
`09:20
`the date, actually. I -- it was before a year ago.
`09:20
` Q I'm sorry. What did you mean by 2015?
`09:21
` A Well, there is a patent here that says it was
`09:21
`issued on -- in 2015.
`09:21
` Q I'm sorry. Where are you reading from?
`09:21
` A Page 1.
`09:21
` Q Okay. That's the '412 patent?
`09:21
` A I -- I assume -- but let me take back what I
`09:21
`just said. I don't -- it was between one to two years
`09:21
`ago. I don't know the exact date.
`09:21
` Q Okay. All right. Yeah.
`09:21
` And please -- I mean, I -- you're here as an
`09:21
`expert.
`09:21
` A Sure.
`09:21
` Q You understand that; right?
`09:21
` A Yes.
`09:21
` Q You're not here as what lawyers would call a
`09:21
`percipient fact witness.
`09:21
` Do you understand that? Do you understand
`09:21
`what that means?
`09:21
` A No. Please explain.
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`12
` Q It would be someone who perceived something,
`09:21
`saw it, touched, heard, felt something. You're here
`09:21
`for your expertise --
`09:21
` A That's something --
`09:21
` THE REPORTER: Okay. One at a time, please.
`09:21
` MR. COYNE: Sorry.
`09:21
` Q You understand you're here for your expertise
`09:21
`in this area; correct?
`09:21
` A Correct.
`09:21
` Q And not here as a percipient fact witness?
`09:21
` A I understand.
`09:21
` Q Okay. So, I'd rather you not try to
`09:21
`reconstruct something. If you don't remember, just
`09:21
`tell me; okay?
`09:21
` A I don't remember.
`09:21
` Q Okay. So, it would have been sometime after
`09:21
`September 1, because that's when the patent was
`09:21
`issued, 2015?
`09:21
` A Oh, yes.
`09:22
` Q Okay. And before April 26, 2016, when you
`09:22
`signed your declaration?
`09:22
` A Yes.
`09:22
` Q Okay. Do you -- how many months were you
`09:22
`working -- 23. I'm sorry. I misspoke.
`09:22
` How many months were you working on this
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`13
`project before you signed your declaration?
`09:22
` MR. DESAI: Objection; vague.
`09:22
` THE WITNESS: Which -- can you please --
`09:22
`which project are you talking about?
`09:22
` MR. COYNE: This one.
`09:22
` THE WITNESS: This particular --
`09:22
` MR. COYNE: This particular IPR.
`09:22
` THE WITNESS: As I mentioned, I worked on a
`09:22
`number of them at the same time. I -- typically, they
`09:22
`take about two to three months, in that order.
`09:22
` MR. COYNE: Okay.
`09:22
` Q And just so we're clear today --
`09:22
` A On that order.
`09:22
` Q Sorry. I'm tending to lose my voice. So, if
`09:22
`I do and we need to take a break, I -- I apologize in
`09:22
`advance.
`09:22
` The questions I have for you today relate
`09:22
`to -- to this particular IPR.
`09:22
` A I understand.
`09:22
` Q IPR 2016-00952; okay?
`09:22
` Unless I make a specific reference to another
`09:22
`proceeding, that's the subject that we're talking
`09:23
`about today.
`09:23
` A Okay.
`09:23
` Q The '412 patent.
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`14
` Do you understand that?
`09:23
` A I do.
`09:23
` Q Okay.
`09:23
` A But, if I may say that, as I worked on a
`09:23
`number of them, I don't remember the sequence.
`09:23
` Q Okay. That's fair enough.
`09:23
` But it would -- your -- best of your
`09:23
`recollection, you would have started working on this
`09:23
`particular IPR a couple of months before April 23rd,
`09:23
`2016; correct?
`09:23
` A Typically, two to three months.
`09:23
` Q Okay. Thank you.
`09:23
` When did you first form your opinion in this
`09:23
`matter?
`09:23
` MR. DESAI: Objection; vague.
`09:23
` THE WITNESS: About what? Specific opinion
`09:23
`about what? Because I have many opinions in here.
`09:23
` MR. COYNE: Q. You understand that you're
`09:23
`rendering opinions in this proceeding; right?
`09:23
` A Sure. Which particular opinion?
`09:23
` Q All of them.
`09:23
` A Well, when I signed this.
`09:23
` Q So, you didn't reach -- you didn't reach any
`09:23
`of these opinions until the -- the moment that you put
`09:23
`pen to paper and signed it?
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`

`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`15
` A It's a process of coming to an opinion. So
`09:23
`you don't just come up with an opinion. You read.
`09:23
`You refer. You go back. And finally, when you put
`09:23
`down you are satisfied with all your -- I was very --
`09:24
`I was satisfied with all my opinions. But, along the
`09:24
`way, I had to -- to make -- to make my opinions as I
`09:24
`went based on the supporting evidence, so --
`09:24
` Q When did you first reach an opinion that you
`09:24
`were going to support GE in this proceeding?
`09:24
` A I don't remember. I don't remember. It
`09:24
`was -- because there are a number of claims in here,
`09:24
`because you said "any," which means even one.
`09:24
` Q Yeah.
`09:24
` A So, I don't remember. It's sometime during
`09:24
`the process, this two- or three-month process.
`09:24
` Q Okay. What did you do to reach your opinions
`09:24
`in this case?
`09:24
` A Well, the process has been basically go
`09:24
`through the prior art, read the patent carefully, and
`09:24
`consider the full context of the patent and the
`09:24
`context of the prior art, and go through one by one,
`09:24
`and reach an opinion.
`09:25
` If there was any questions, then go through
`09:25
`it through a loop process.
`09:25
` Q Go through what one by one?
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`Abhari, Reza
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`Case IPR2016-00952
`
`January 4, 2017
`
`16
` A Each claim.
`09:25
` Q Okay.
`09:25
` A Claim by claim.
`09:25
` Q And that's what you did here?
`09:25
` A Well, this was relatively -- it's one of the
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`simplest in terms of the number of patents that I've
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`looked at. And so it was relatively -- there was one
`09:25
`or two issues at the beginning. The rest were
`09:25
`relatively simple to achieve an opinion.
`09:25
` Q What were the one or two issues?
`09:25
` A It's mainly the Claim 1 in terms of -- and
`09:25
`I'm sure we will get through it.
`09:25
` Q What were the one or two issues?
`09:25
` A The claims that were made relative to the
`09:25
`prior art.
`09:25
` Q What were the issues with respect --
`09:25
` A Well, I mean --
`09:25
` Q -- to the claims that were made relative to
`09:25
`the prior art?
`09:25
` When you said "one or two issues," what did
`09:26
`you mean?
`09:26
` A Well, generally, what I meant was that, in
`09:26
`any patent -- that this is a general statement, that I
`09:26
`have found in the past that there are always one or
`09:26
`two issues that come up in terms of the definitions
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`17
`that are used, for example.
`09:26
` This is often the biggest challenge, because
`09:26
`the definitions are not always what is known in the --
`09:26
`in the art. It is a legally constructed definition as
`09:26
`opposed to -- to a technical description.
`09:26
` For example, N over R, that has been used in
`09:26
`this claim, is not a common terminology which is used.
`09:26
` Q So you're saying that one of the issues was
`09:26
`the definition of N over R?
`09:26
` A For ex- -- I'm just putting it as an example
`09:26
`of a case where a definition was used, which is
`09:26
`nonstandard.
`09:26
` Q Okay. What were the other issues?
`09:26
` A The other issues, for example, is the
`09:27
`definition of the word "spool."
`09:27
` Q Okay. Are there any other issues?
`09:27
` A Well, I think in the claim construct- -- in
`09:27
`the -- if I go back, if I may. I don't want to go by
`09:27
`memory.
`09:27
` The spool, for example, is just one.
`09:27
` Definition of the position of inlet and
`09:27
`outlets that were used. This was another issue.
`09:27
` Q What other issues?
`09:27
` A Relatively minor. I don't think this is much
`09:27
`of an issue, but it's, like, just what -- propulsor,
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`Abhari, Reza
`
`Case IPR2016-00952
`
`January 4, 2017
`
`18
`but --
`09:27
` Q Propulsor?
`09:27
` A Yes, but that's -- really was not much of it.
`09:27
` The main -- I would say the definitions that
`09:27
`were used in spool and definitions of pressure, where
`09:27
`you define pressure.
`09:28
` Q Okay. There was no issue with respect to
`09:28
`definition of solidity; correct?
`09:28
` A No.
`09:28
` Q That's generally understood --
`09:28
` A That's generally understood.
`09:28
` Q -- in your field of science; correct?
`09:28
` A Correct.
`09:28
` Q Okay. No ambiguity?
`09:28
` MR. DESAI: Guys, I can see the court
`09:28
`reporter shaking her head because you're --
`09:28
` THE WITNESS: Yes.