Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________
`
` GENERAL ELECTRIC COMPANY,
`
` Petitioner,
`
` v.
`
` UNITED TECHNOLOGIES CORPORATION,
`
` Patent Owner.
`
` __________
`
` IPR2016-01289
`
` Patent No. 7,060,360
`
` __________
`
` Washington, D.C.
`
` March 1, 2017
`
` CROSS-EXAMINATION OF
`
` ANDREAS M. GLAESER, Ph.D.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`1
`
`2
`
`3
`
`4
`
`5 6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`1
`
`UTC 2014
`General Electric v. United Technologies
`IPR2016-01289
`
`
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________
`
` GENERAL ELECTRIC COMPANY,
`
` Petitioner,
`
` v.
`
` UNITED TECHNOLOGIES CORPORATION,
`
` Patent Owner.
`
` __________
`
` IPR2016-01289
`
` Patent No. 7,060,360
`
` __________
`
` Washington, D.C.
`
` March 1, 2017
`
` CROSS-EXAMINATION OF
`
` ANDREAS M. GLAESER, Ph.D.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`1
`
`2
`
`3
`
`4
`
`5 6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`1
`
`UTC 2014
`General Electric v. United Technologies
`IPR2016-01289
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 2
`
` Cross-Examination of ANDREAS M.
`
`GLAESER, Ph.D., a witness herein, called for
`
`examination by counsel for Patent Owner in the
`
`above-entitled matter, was taken on Wednesday,
`
`March 1, 2017, commencing at 9:05 a.m. at the law
`
`offices of Weil Gotshal & Manges, LLP, 1300 Eye
`
`Street, NW, Suite 900, Washington, D.C. 20005 by
`
`Cappy Hallock, Registered Professional Reporter,
`
`Certified Realtime Reporter, Certified Livenote
`
`Reporter and Notary Public in and for the
`
`District of Columbia.
`
`1 2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`2
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 3
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` A P P E A R A N C E S:
`
` ON BEHALF OF THE PATENT OWNER:
`
` LAUREN A. DEGNAN, ESQUIRE
`
` Fish & Richardson, P.C.
`
` 1425 K Street NW, 11th Floor
`
` Washington, D.C. 20005
`
` 202-783-5070
`
` degnan@fr.com
`
` -and-
`
` DAVID L. HOLT, ESQUIRE
`
` Fish & Richardson, P.C.
`
` 601 Lexington Avenue, 52nd Floor
`
` New York, New York 10022
`
` 212-765-5070
`
` david.holt@fr.com
`
` -and-
`
` GRETCHEN A. DeVRIES, Ph.D.
`
` Fish & Richardson, P.C.
`
` One Marina Park Drive
`
` Boston, Massachusetts 02210-1878
`
` 617-542-5070 (P) 617-542-8906 (F)
`
` DeVries@fr.com
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`3
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 4
`
` A P P E A R A N C E S: (Continued)
`
` ON BEHALF OF THE PETITIONER:
`
` ANISH DESAI, ESQUIRE
`
` MEGAN H. WANTLAND, ESQUIRE
`
` Weil, Gotshal & Manges LLP
`
` 300 Eye Street, NW, Suite 900
`
` Washington, D.C. 20005
`
` 202-682-7271 (P) 202-360-0348 (F)
`
` anish.desai@weil.com
`
` megan.wantland@weil.com
`
`ALSO PRESENT:
`
` Troy Prince, Esq.
`
` Pratt & Whitney
`
`Videographer: TJ O'Toole, CLVS
`
`Reported by: Cappy Hallock, RPR, CRR, CLR
`
`1
`
`2 3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`4
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 5
`
` C O N T E N T S
`
` Deposition of ANDREAS M. GLAESER, Ph.D.
`
` March 1, 2017
`
`EXAMINATION BY: PAGE
`
` Ms. Degnan 7
`
` -o0o-
`
` PREVIOUSLY MARKED EXHIBITS
`
`GE PAGE
`
`Exhibit 1003 Glaeser declaration9 10
`
`Exhibit 1025 Webster reference 40
`
`Exhibit 1005 Terentieva patent 51
`
`Exhibit 1006 Eaton patent 72
`
`Exhibit 1024 Suzuki reference 91
`
` -o0o-
`
`1
`
`2
`
`3
`
`4 5 6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`5
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 6
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` P R O C E E D I N G S
`
` - - - - - -
`
` THE VIDEO OPERATOR: All right, stand
`
`by, please.
`
` On the record with Disc 1 of the video
`
`deposition of Andreas Glaeser, taken by the
`
`Patent Owner in the matter of General Electric
`
`Company versus United Technologies Corporation,
`
`being heard before the United States Patent &
`
`Trademark Office, before the Patent Trial and
`
`Appeal Board, Case Number IPR2016-01289.
`
` This deposition is being held at the
`
`Law Offices of Weil Gotshal located at 1300 Eye
`
`Street, Northwest, in Washington, D.C. on March
`
`1st, 2017 at approximately 9:07 a.m.
`
` My name is TJ O'Toole. I'm the
`
`Certified Legal Video Specialist. The court
`
`reporter is Cappy Hallock. We are both here
`
`representing GregoryEdwards LLC.
`
` Will counsel please introduce
`
`themselves and indicate which parties they
`
`represent.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`6
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 7
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` MS. DEGNAN: Good morning. This is
`
`Lauren Degnan with Fish & Richardson. I
`
`represent the Patent Owner, United Technologies
`
`Corporation. I am joined by two of my colleagues
`
`from Fish & Richardson, David Holt and Gretchen
`
`DeVries, as well as Troy Print with United
`
`Technologies.
`
` MR. DESAI: Anish Desai here from Weil
`
`Gotshall representing General Electric. Also
`
`with me is Meghan Wantland from Weil Gotshall.
`
` THE VIDEO OPERATOR: Thank you.
`
` Will the court reporter please swear
`
`in the witness.
`
`WHEREUPON,
`
` ANDREAS M. GLAESER, Ph.D.,
`
` A Witness called for examination,
`
`having been first duly sworn, was examined and
`
`testified as follows:
`
` EXAMINATION
`
`BY MS. DEGNAN:
`
` Q Good morning.
`
` A Good morning.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`7
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 8
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` Q Dr. Glaeser, would you please state
`
`your full name for the record?
`
` A Andreas Glaeser.
`
` Q I am going to go over a few ground
`
`rules for the deposition today, if you don't
`
`mind.
`
` A Okay.
`
` Q You understand you are under oath
`
`today?
`
` A Yes.
`
` Q And you are supposed to tell the
`
`truth, the whole truth and nothing but the truth,
`
`right?
`
` A Yes.
`
` Q And just like we are in court?
`
` A Um-hmm.
`
` Q Yes?
`
` And you must give truthful, accurate
`
`and complete testimony. Do you understand that?
`
` A Yes.
`
` Q If you don't understand a question
`
`will you please let me know? Yes?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`8
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 9
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` A I will, yes.
`
` Q And if you do answer it is fair to
`
`conclude that you understood the question, right?
`
` A Yes.
`
` Q If at any time you want to change an
`
`answer that you gave or you want to add to your
`
`answer just let me know.
`
` A Okay.
`
` Q We will take breaks throughout the
`
`day, probably every hour. That's kind of what I
`
`usually need, but if you need one earlier just
`
`let me know.
`
` A All right. I will do that.
`
` Q Is there any reason you cannot give
`
`true, accurate and complete testimony today?
`
` A No.
`
` Q Are you on any medication that might
`
`impair your ability to do so?
`
` A No.
`
` Q If that changes will you let me know?
`
` A Yes, I will.
`
` MR. DESAI: Me, too.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`9
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 10
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` MS. DEGNAN: So I am going to hand to
`
`you what has been previously marked Exhibit
`
`GE-1003.
`
` (Previously marked GE Exhibit No.
`
`1003, first referral.)
`
`BY MS. DEGNAN:
`
` Q Do you recognize it?
`
` A Yes. This is the declaration that I
`
`prepared.
`
` Q How long did you spend, approximately,
`
`preparing this declaration?
`
` A I have a hard time saying exactly how
`
`many hours I did because it was distributed over
`
`a number of months. It was more than ten hours.
`
`It was less than one hundred in all likelihood.
`
`That's about as good a range as I could give you
`
`and give you an honest answer.
`
` Q Fair enough.
`
` Does that range of between ten and one
`
`hundred hours include the time you spent
`
`analyzing the prior art that you discussed in
`
`that declaration?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`10
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 11
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` A It includes that time, yes.
`
` Q Okay.
`
` So if we may turn to Pages 2 and 3 and
`
`4 of your declaration there is a table that
`
`indicates documents you say you reviewed.
`
` A Yes.
`
` Q Did you locate those documents
`
`yourself or did the attorneys with whom you are
`
`working provide them?
`
` A I located some of them, quite a few of
`
`them actually, and others were provided, for
`
`example, the original patents and so on. Most of
`
`those documents I received from the attorneys,
`
`but the majority of what is here are things that
`
`I looked up and found through online searches.
`
` Q Okay.
`
` Can you identify, I guess, besides the
`
`patent you mentioned, and is there anything else
`
`on the list that you remember that the attorneys
`
`provided to you?
`
` A Well, 1, 2 and 5 were provided. And
`
`8 -- when I say 8 I mean GE-1008.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`11
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 12
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` The rest of these are things that I
`
`either already had in my files as a result of
`
`work that I had done previously, or found by
`
`searching the literature. So the ones that I
`
`identified are the ones that I remember being
`
`provided by counsel.
`
` Q So this declaration, Exhibit 1003,
`
`does it represent all the analysis you performed
`
`in reaching your conclusions for this case?
`
` A There were other papers that I read
`
`and other things that I did that were in earlier
`
`drafts of the declaration that ultimately got
`
`culled, so there were more references and there
`
`were other things that I looked at that I would
`
`have expected a person of ordinary skill in the
`
`art to have accessed and looked at in terms of
`
`evaluating this. So there are other things that
`
`I looked at and evaluated or relied on in terms
`
`of information that I had had previously or used
`
`in work of my own that I relied on that aren't
`
`represented in this document or in this listing.
`
` Q With respect to the conclusions you
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`12
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`reached regarding invalidity of the claims of the
`
`'360 patent, is it fair to say that your entire
`
`opinion is now reflected in your declaration?
`
` A There are -- there are things and
`
`considerations that add to what is in here that
`
`are not explicitly included in this declaration.
`
` Q And do you think this declaration is
`
`deficient in some way?
`
` A No. I don't think it is deficient. I
`
`think it is when you have a question or a
`
`question is raised, for example, by Professor
`
`Clarke, then you look to see whether there is
`
`additional information that can weigh on certain
`
`issues that he raised. And obviously since that
`
`came after the fact it's not included in this
`
`declaration but it's literature that I looked at
`
`and evaluated.
`
` Q At the time that you executed your
`
`declaration here, Exhibit 1003, did you believe
`
`that your analysis that you set forth in the
`
`declaration was sufficient to show that the
`
`claims of the 630 patent are invalid?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`13
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 14
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` A The '360 patent, yes.
`
` Q Did you perform any calculations in
`
`connection with preparing this declaration that
`
`you omitted from the declaration?
`
` A Not that I recall.
`
` Q Did you intentionally omit any
`
`analysis that would show that the claims of the
`
`'360 patent are invalid over the prior art that
`
`you highlight in your declaration?
`
` A I'm sorry, could you repeat the
`
`question?
`
` Q Sure. Did you intentionally omit any
`
`of your analysis showing that the claims of the
`
`'360 patent are invalid over the art described in
`
`your declaration?
`
` A No, not that I know of.
`
` Q Did you omit any testing results --
`
`excuse me. Strike that.
`
` Did you omit any results of any
`
`testing you performed in connection with your
`
`invalidity analysis of the declaration?
`
` A Testing meaning experimental work and
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`14
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 15
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`something that would be done in a lab?
`
` Q Yes.
`
` A No, I didn't do any lab work
`
`associated with this.
`
` Q Did you do any other kind of testing
`
`associated with this declaration?
`
` MR. DESAI: Objection, vague.
`
` A The only kind of testing I'm aware of
`
`would be testing against what is in the
`
`literature and what has been reported in the
`
`literature and doing experimental testing. I did
`
`not do any experimental testing. There are
`
`papers that I read that would touch on the claims
`
`of the '360 patent that are not included in this
`
`declaration because we thought they were
`
`redundant and didn't need to be included. The
`
`point was already made by enough references that
`
`we felt this was sufficient.
`
` Q Are you aware of any errors in your
`
`declaration?
`
` A There are some typos. But where there
`
`might be a word missing, "pressure" I think is
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`15
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 16
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`missing in one place, and water vapor. And I
`
`think it's supposed to be water vapor pressure,
`
`but other than that I'm not aware of any major --
`
`any major errors. And I've read through it
`
`several times, so ...
`
` Q Do you want to tell me where that word
`
`should go?
`
` A I would really have to search through
`
`that, and I would want to look at the original
`
`reference to make sure that it's -- that it is,
`
`in fact, a typo. But I was reading it and said I
`
`think there is supposed to be a "pressure" here,
`
`and perhaps it didn't make it in here.
`
` Q But you're not aware of any
`
`substantive errors in the declaration?
`
` A No. These are not -- I think the
`
`intent was clear enough that if it was a typo you
`
`kind of read past it and didn't really -- didn't
`
`really notice that anything substantive was
`
`missing from the document.
`
` Q Today you stand by everything you said
`
`in the declaration?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`16
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 17
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` A Yes.
`
` Q All right. Let's turn to Paragraph 4
`
`of your declaration.
`
` A Yes.
`
` Q In this paragraph you discuss the
`
`qualifications of a person of ordinary skill in
`
`the art, correct?
`
` A Um-hmm.
`
` Q You mention that such a person would
`
`have at least three to five years of experience
`
`in the field of high-temperature materials and
`
`composites, right?
`
` A Yes.
`
` Q Is it your opinion that this field
`
`necessarily includes knowledge of coatings?
`
` A That this field experience -- that
`
`experience in the field of high-temperature
`
`materials and composites would include explicitly
`
`coatings, is that what your --
`
` Q Yes.
`
` A I think it -- I think the person would
`
`need to be aware of the issues that arise in
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`17
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 18
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`coatings, and those would be issues like chemical
`
`incompatibility. Those would be issues of
`
`thermal expansion compatibility. There would be
`
`issues of residual stresses in coating systems.
`
`There would be issues of evolution in coating
`
`systems that are used at high temperature. And
`
`that kind of experience could be achieved and
`
`there would be parallels to that in other fields
`
`of high-temperature materials that aren't
`
`explicitly coating related.
`
` So I don't think the person would
`
`necessarily have to be an expert in the field of
`
`coatings because it's the fundamental issues of
`
`chemical compatibility, thermal expansion,
`
`mismatch, stress and strain, stability that are,
`
`in my view at least, overarching issues, and they
`
`are not specific or limited to just the field of
`
`coatings. Familiarity with coatings would
`
`obviously be beneficial if one were working in
`
`this. It's hard to imagine someone wouldn't
`
`become familiar with the literature in the
`
`coatings area.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`18
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 19
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` Q You said knowledge of coatings would
`
`be beneficial. But would someone of ordinary
`
`skill in the art have such knowledge or would he
`
`have to have such knowledge to qualify as one of
`
`ordinary skill in the art under your definition?
`
` MR. DESAI: Objection, form.
`
` A I think that someone who has worked,
`
`for example, in the field of joining, who has
`
`worked in the field of high-temperature
`
`composites, who has worked on designing
`
`composites, who has worked on designing of
`
`multilayers, if they are not in the deposition
`
`field, they are not in that aspect of coating
`
`technology, they are not a practitioner of
`
`coating but they are aware of the issues that
`
`arise in coatings.
`
` So again, I come back to this someone
`
`who is familiar with the issues that are involved
`
`in coating, do I have to have put a coating on
`
`something to be able to comment on this patent?
`
`No, I don't think so.
`
` Q You had mentioned something in your
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`19
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 20
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`earlier answer that, if I wrote it down
`
`correctly, is evolution of coatings.
`
` A Um-hmm.
`
` Q What did you mean by that?
`
` A When you put dissimilar materials
`
`together you have a dissimilar material
`
`interface, so I have material A and material B.
`
`That kind of an interface would also arise, for
`
`example, in a composite material where I have a
`
`fiber or a particulate material and I have two
`
`phases that are involved, two chemically,
`
`structurally distinct materials or more than two
`
`phases involved.
`
` Then there are issues that occur at
`
`the interface between those two phases. For
`
`example, are the materials chemically compatible?
`
`Do they react with one another? Is there a
`
`reaction layer? If I have this material at
`
`elevated temperature do I diffuse one component
`
`into the other? To what extent does that happen?
`
`To what extent does that undermine the properties
`
`of the material?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`20
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 21
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` There are parallel issues when you
`
`have coatings in the sense that if I have A and
`
`B, they may evolve over time as a result of those
`
`kind of interactions. And there are many
`
`examples in the thermal barrier coating
`
`literature, particularly the older literature
`
`that deals with nickel-based superalloy type
`
`turbine blades where reaction layers develop.
`
` But a person who understands
`
`high-temperature materials, who understands
`
`thermodynamics wouldn't necessarily have to be a
`
`coatings expert in order to appreciate that
`
`problem and be able to voice on that problem and
`
`express an opinion on that problem.
`
` Q Is it your view that someone with at
`
`least three to five years of experience in the
`
`field of high-temperature materials and
`
`composites necessarily works with coatings?
`
` A No, I don't think they necessarily
`
`work with coatings.
`
` Q As of May 22nd, 2003 do you believe
`
`you met the qualifications you set forth
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`21
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 22
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`regarding a person of ordinary skill in the art?
`
` A I think I -- I think I do for various
`
`reasons. Academically I've taught courses in
`
`thermodynamics, which is a critical issue in
`
`these kinds of materials used in high-temperature
`
`environments. I have taught courses in phase
`
`transformations, diffusion and these kind of
`
`interactions between materials that are adjoining
`
`to one another, can involve phase transformations
`
`and do involve diffusion of one specie to
`
`somewhere else.
`
` I've taught courses on phase diagrams,
`
`which phase diagrams tell you, give you a map for
`
`what is stable at what temperature in a given
`
`composition system. I've worked on joining of
`
`materials using multilayer foils, so there is
`
`a -- there is a coating aspect in that work.
`
`There we design these to evolve in a particular
`
`way and produce joints between ceramic
`
`materials --
`
` Q Can I interrupt you for a second? I
`
`think you may have misunderstood my question.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`22
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 23
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`I'm not asking whether today you meet the
`
`definition but in May 22nd of 2003 do you believe
`
`you met the definition that you provided for a
`
`person of ordinary skill in the art.
`
` A I was engaged in all of these -- all
`
`of these activities that I was describing and a
`
`host of others by 2003, yes. So you always learn
`
`more over time, but I think at the time that this
`
`patent was, or was issued or filed for that -- at
`
`that time I did have the background that would
`
`have been necessary.
`
` Q Okay. Let's turn to Paragraph 8 of
`
`your declaration, Exhibit 1003.
`
` A Um-hmm.
`
` Q In this paragraph you mention work
`
`that you performed that is relevant to thermal
`
`barrier coatings.
`
` Do you see that?
`
` A Yes.
`
` Q What are thermal barrier coatings?
`
` A They are coatings applied to turbine
`
`blades and other components in high-temperature
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`23
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 24
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`engines with the intention of dropping the
`
`temperature of the component. So, for example,
`
`in the case of nickel-based superalloys, to
`
`extend the lifetime of those alloys by keeping
`
`them at temperatures where they have adequate
`
`performance. Those original thermal barrier
`
`coatings were typically made of a zirconium
`
`material which is the material that I worked on
`
`and was the basis for this work that was relevant
`
`to thermal barrier coatings. In particular it
`
`dealt with yttria-stabilized zirconia. So I
`
`don't know if I have -- if that's a sufficient
`
`answer for you or if you would like me to go into
`
`more detail and provide, you know -- and provide
`
`additional --
`
` Q You mention that the thermal barrier
`
`coatings drop the temperature?
`
` A Yes.
`
` Q So that the --
`
` A Relative to the engine and air
`
`temperature, yes.
`
` Q So if I understand this, you would
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`24
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 25
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`have high temperature in the air, you would have
`
`the thermal coating, and you would have the
`
`turbine blade itself that is being protected?
`
` A The temperature is being dropped at
`
`the surface of the turbine blade, yes.
`
` Q So the temperature at the top of the
`
`coating is much higher than the temperature at
`
`the blade itself?
`
` A It depends on how thick the thermal
`
`barrier is and how effective it is, but there is
`
`a thermal temperature gradient that goes through
`
`the barrier, yes.
`
` Q Now, from a design perspective is it
`
`the goal to make that temperature drop
`
`significant?
`
` A There are, at least in the case of the
`
`nickel-based superalloys, temperatures that you
`
`don't want to exceed because the microstructure
`
`changes. I don't recall what that temperature is
`
`exactly, but the goal of bringing the thermal --
`
`putting a thermal barrier coating on is to allow
`
`you to run the engine at higher temperature than
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`25
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 26
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`that magic temperature for whatever alloy you are
`
`using, so that you can get higher efficiency out
`
`of the engine and do so using well-known
`
`materials that have been very well-developed over
`
`the years in the metallurgical community.
`
` Q And the alloy we are talking about is
`
`the alloy of the blade itself?
`
` A That would be a nickel-based -- yes,
`
`typically a nickel-based superalloy.
`
` Q And you mentioned that using a thermal
`
`barrier coating allows one to extend the life of
`
`the blade; is that right?
`
` A Yes.
`
` Q And it does that by reducing thermal
`
`fatigue?
`
` A Reduces creep, reduces coarsening,
`
`reduces a number of things that occur in the
`
`microstructure of the nickel-based superalloy.
`
` Q Is one of those things reducing
`
`thermal fatigue?
`
` A I don't know exactly whether that's
`
`one of the key issues. I know that creep is one
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`26
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 27
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`of the key issues. I know that you don't want a
`
`phase change to occur that would occur if the
`
`alloy got too hot.
`
` Q Does the thermal barrier coating also
`
`extend the life by reducing oxidation on the
`
`substrate, the blade?
`
` A That depends on how you define the
`
`thermal barrier coating versus the thermal
`
`barrier coating system. Typical thermal barrier
`
`coatings are either plasma sprayed,
`
`yttria-stabilized zirconia, which means that you
`
`have droplets of things being sprayed onto the
`
`surface. Those tend to form very open kinds of
`
`structures.
`
` If you imagine throwing partially
`
`molten marbles or something at a surface and they
`
`stick to one another, they have internal cracks,
`
`they have significant porosity. And then
`
`those -- the other technique for making these is
`
`called E-beam PVD --
`
` THE REPORTER: Is called?
`
` A E-beam PVD, and that produces a
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`27
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 28
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`columnar structure. It's almost like trees, if
`
`you can imagine, a forest of closely spaced pine
`
`trees with that kind of structure. They actually
`
`open up, so at least initially they open up.
`
`They tend to age and then center which is one of
`
`the problems in thermal barrier coating long-term
`
`stability.
`
` But the material, yttria-stabilized
`
`zirconia, provides essentially no resistance to
`
`oxygen. The primary purpose of these is to drop
`
`the temperature.
`
` Q So are you aware of any thermal
`
`barrier coatings that also reduce oxidation?
`
` A Well, the way thermal barrier coatings
`
`are done, and again, this is why I contrasted the
`
`thermal barrier, which is the yttria-stabilized
`
`zirconia, from the thermal barrier coating
`
`system, because the system includes a layer that
`
`develops an alumina layer. It's referred to in
`
`the trade as a TGO, a thermally grown oxide, and
`
`this is a layer of aluminum oxide that develops
`
`when oxygen comes in from the outside and
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`28
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 29
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`oxidizes the aluminum that is in the alloy.
`
`There is an alloy layer that's placed on the
`
`outside of the nickel-based superalloy. And that
`
`is one of the primary functions of that alloy is
`
`to form this thermally grown oxide.
`
` Aluminum oxide along with silica,
`
`Si02, have very low diffusion coefficients for
`
`oxygen, so that layer when it forms and as it
`
`thickens prevents an ingress of oxygen into the
`
`underlying nickel-based superalloy. And so it's
`
`that layer, that TGO, that the actual thermal
`
`barrier coating material, the yttria-stabilized
`
`zirconia, is attached to in thermal barrier
`
`coatings on nickel-based superalloys --
`
` Q So putting aside --
`
` A -- so that combination of that alumina
`
`layer, and that has the effect of both dropping
`
`the temperature and preventing oxidation, so
`
`together they work as a system.
`
` Q So thermal barrier coating systems,
`
`you would agree, do both drop the temperature and
`
`provide reduction of oxidation, right?
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`29
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 30
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
` A Effective ones, yes.
`
` Q The ones that you design.
`
` But the thermal barrier coatings by
`
`themselves, in your view, do not reduce
`
`oxidation?
`
` A Yttria-stabilized zirconia, and this
`
`is discussed in many places, and in particular
`
`these PVD structures, because they open up --
`
`they actually have gaps between these columns
`
`that can open up as the material heats, heats or
`
`cools, depending on which way the thermal
`
`expansion mismatches go -- essentially provide no
`
`barrier to oxygen, and oxygen diffusion in
`
`zirconia is very rapid.
`
` Q So you are directing me back to a
`
`specific kind of thermal barrier coating. I want
`
`to ask more broadly.
`
` Is it your view that there is no
`
`thermal barrier coating out there that also
`
`reduces oxidation?
`
` MR. DESAI: Objection, outside the
`
`scope of the declaration.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`30
`
`
`
`Andreas M. Glaeser, Ph.D. - March 1, 2017
`
`Page 31
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`1
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
