Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` - - - - - - - - - - - - - - - X
`
` GENERAL ELECTRIC COMPANY, :
`
` Petitioner, : Case No.
`
` v. : IPR2016-01301
`
` UNITED TECHNOLOGIES :
`
` CORPORATION, : Patent No.
`
` Patent Owner. : 6,939,392
`
` - - - - - - - - - - - - - - - X
`
` Washington, D.C.
`
` Thursday, June 29, 2017
`
` Deposition of VIGOR YANG, Ph.D., a
`
`witness herein, called for examination by counsel for
`
`Petitioner in the above-entitled matter, pursuant to
`
`notice, the witness being duly sworn by
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`JESSICA CROXFORD, a Notary Public in and for the
`
`District of Columbia, taken at the offices of
`
`Finnegan, Henderson, Farabow, Garrett & Dunner,
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`L.L.P.,901 New York Avenue, Northwest, Washington,
`
`D.C., at 10:09 a.m., Thursday, June 29, 2017, and the
`
`proceedings being taken down by Stenotype by
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.001
`
`
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` - - - - - - - - - - - - - - - X
`
` GENERAL ELECTRIC COMPANY, :
`
` Petitioner, : Case No.
`
` v. : IPR2016-01301
`
` UNITED TECHNOLOGIES :
`
` CORPORATION, : Patent No.
`
` Patent Owner. : 6,939,392
`
` - - - - - - - - - - - - - - - X
`
` Washington, D.C.
`
` Thursday, June 29, 2017
`
` Deposition of VIGOR YANG, Ph.D., a
`
`witness herein, called for examination by counsel for
`
`Petitioner in the above-entitled matter, pursuant to
`
`notice, the witness being duly sworn by
`
`JESSICA CROXFORD, a Notary Public in and for the
`
`District of Columbia, taken at the offices of
`
`Finnegan, Henderson, Farabow, Garrett & Dunner,
`
`L.L.P.,901 New York Avenue, Northwest, Washington,
`
`D.C., at 10:09 a.m., Thursday, June 29, 2017, and the
`
`proceedings being taken down by Stenotype by
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.001
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 2
`
`JESSICA CROXFORD, RPR, and transcribed under her
`
`direction.
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.002
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 3
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`APPEARANCES:
`
` On behalf of the Petitioner:
`
` CHRISTOPHER T. MARANDO, ESQ.
`
` BRIAN E. FERGUSON, ESQ.
`
` Weil, Gotshal & Manges LLP
`
` 1300 Eye Street, Northwest
`
` Suite 900
`
` Washington, D.C. 20005-3314
`
` (202) 682-7094
`
` christopher.marando@weil.com
`
` ge.wgm.service@weil.com
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.003
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 4
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`APPEARANCES (Continued):
`
` On behalf of the Patent Owner:
`
` C. BRANDON RASH, ESQ.
`
` CARA LASSWELL, ESQ.
`
` M. ANDREW HOLTMAN, PH.D., ESQ.
`
` Finnegan, Henderson, Farabow,
`
` Garrett & Dunner, L.L.P.
`
` 901 New York Avenue, Northwest
`
` Washington, D.C. 20001-4413
`
` (202) 408-4000
`
` cara.lasswell@finnegan.com
`
` brandon.rash@finnegan.com
`
` andy.holtman@finnegan.com
`
` ALSO PRESENT:
`
` Stephanie Adamakos
`
` Darrell Stark, General Electric
`
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.004
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 5
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` C O N T E N T S
`
`WITNESS EXAMINATION BY COUNSEL FOR
`
`VIGOR YANG, Ph.D. PETITIONER
`
` BY MR. MARANDO 6
`
` E X H I B I T S
`
` (None marked.)
`
` - - -
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.005
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 6
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` P R O C E E D I N G S
`
`Whereupon,
`
` VIGOR YANG, Ph.D.,
`
`was called as a witness by counsel for Petitioner,
`
`and having been duly sworn by the Notary Public, was
`
`examined and testified as follows:
`
` EXAMINATION BY COUNSEL FOR PETITIONER
`
`BY MR. MARANDO:
`
` Q. Good morning. Could you please state your
`
`name for the record.
`
` A. Vigor Yang, Y-A-N-G.
`
` Q. Thank you. Dr. Yang, have you been
`
`deposed before?
`
` A. This is my first time.
`
` Q. Okay. And have you testified in court
`
`before?
`
` A. No.
`
` Q. Okay. All right. So since this is the
`
`first deposition, I'll just go over some basic ground
`
`rules that will help things move along --
`
` A. Sure.
`
` Q. -- quickly. So you understand today that
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.006
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 7
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`I'm going to be asking you questions, and your job
`
`here is to answer those questions?
`
` Do you understand that?
`
` A. Yes.
`
` Q. Okay. And if you don't understand a
`
`question, will you please tell me?
`
` A. I will.
`
` Q. Okay. And as you notice, we're making a
`
`written record. So verbal answers are -- are very
`
`important as opposed to gestures or head nods. So
`
`"yes" or "no," even when it seems like you've
`
`answered with a head nod, it's still necessary.
`
` Do you understand that?
`
` A. Yes, I understand.
`
` Q. Okay. If at any time today you believe a
`
`previous answer you may have given was inaccurate or
`
`incomplete, will you please tell me?
`
` A. I will.
`
` Q. Thank you. Is anything keeping you from
`
`providing truthful and accurate testimony today?
`
` A. Not to my knowledge.
`
` Q. I don't expect this deposition will be
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.007
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 8
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`going too long, but we will probably take a break.
`
`So if you ever need a break, tell me and we can do
`
`that; otherwise, we'll probably break at about an
`
`hour and then at hour intervals thereafter. The only
`
`thing that I would ask is that if there's a question
`
`pending, that we answer that question before we take
`
`a break.
`
` Does that sound okay?
`
` A. That's fine.
`
` Q. Okay.
`
` A. Thank you.
`
` Q. Sure. Now, your counsel may object to
`
`some of my questions throughout the day. But unless
`
`your counsel instructs you not to respond, you
`
`understand that you still need to answer the
`
`question?
`
` A. Yes, I understand.
`
` Q. Great. Dr. Yang, what did you do to
`
`prepare for today's deposition?
`
` A. I -- I've read all the relevant materials
`
`very carefully, then I formed my own opinions
`
`independently. And also, I consulted with my
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.008
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 9
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`attorneys on legal matters.
`
` Q. Okay.
`
` A. Yes.
`
` Q. So I'm not going to ask for any of the
`
`substance of what you talked about with attorneys.
`
`But did you talk or meet with anyone in preparation
`
`for today's deposition?
`
` A. I talked to my attorneys on legal matters;
`
`for example, the procedure issues. On the technical
`
`side, I formed all of the opinions by myself
`
`independently.
`
` Q. Okay. And specifically for this
`
`deposition to prepare, did you have a meeting with
`
`any attorneys?
`
` A. In preparation for this deposition, I met
`
`my attorneys.
`
` Q. And do you recall which attorneys those
`
`were -- or who were those attorneys?
`
` A. Brandon here, Cara, and I also met Andy
`
`before. That's about several weeks ago.
`
` Q. Okay.
`
` A. Yes.
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.009
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 10
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` Q. And -- and specifically to prepare for
`
`today's deposition, when was that meeting with -- was
`
`that meeting -- well, let me withdraw that.
`
` A. Yes.
`
` Q. To prepare for today's deposition, was
`
`there a meeting with Brandon and Cara; is that
`
`correct?
`
` A. Can you clarify preparation for this
`
`deposition? Are you also referring the preparation
`
`of my declaration or only for deposition itself?
`
` Q. Only for the deposition itself.
`
` A. For the deposition itself, I did meet with
`
`my attorneys, yes. And -- just to get me familiar
`
`with the procedure and also on some of the legal
`
`matters.
`
` Q. And when was that meeting?
`
` A. That happened yesterday.
`
` Q. Okay. And you mentioned that your
`
`attorneys Brandon and Cara were present; is that
`
`correct?
`
` A. That's correct.
`
` Q. Was anyone else present at that meeting?
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.010
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 11
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` A. Also, the UTC attorney.
`
` Q. In-house counsel for United Technologies
`
`was also present?
`
` A. Yes. She was here.
`
` Q. Were any nonattorneys present?
`
` A. No.
`
` Q. And approximately how long did your
`
`meeting last?
`
` A. The meeting yesterday started from 9:30
`
`all the way through 4:30 p.m.
`
` Q. Okay. In your meeting yesterday, did you
`
`review any documents to prepare for today's
`
`deposition?
`
` A. In the meeting yesterday, I reviewed my
`
`own declaration.
`
` Q. Did you review any other documents besides
`
`your own declaration to prepare for today's
`
`deposition?
`
` A. I also reviewed relevant materials; for
`
`example, '392 patent, Dr. Voecks' deposition, and
`
`also his declaration as well.
`
` Q. Is that the full list of what you reviewed
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.011
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 12
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`in terms of documents yesterday?
`
` A. Yes.
`
` Q. Did you discuss this deposition with any
`
`nonlawyers?
`
` A. No.
`
` Q. When were you first -- well, let me back
`
`up.
`
` You understand that we're here today
`
`because of a petition for interparty review that GE
`
`has filed?
`
` A. Yes, I understand.
`
` Q. And when were you first contacted about
`
`this IPR proceeding?
`
` A. In March. This year.
`
` Q. March of this year. And who contacted
`
`you?
`
` A. I was first approached by an agent called
`
`an expert agent and the gentleman in Texas.
`
` Q. That was an expert search agency; is
`
`that -- is that right?
`
` A. Yes.
`
` Q. And did you ultimately -- were you
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.012
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 13
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`ultimately contacted by Finnegan attorneys?
`
` A. Yes.
`
` Q. And do you recall who at Finnegan you were
`
`in contact with first?
`
` A. I was first approached by Cara from this
`
`company.
`
` Q. And after Cara contacted you, did you take
`
`any actions or do any investigation before agreeing
`
`to work on this IPR proceeding?
`
` A. Yes, I did.
`
` Q. Okay.
`
` A. But in a very general sense.
`
` Q. What did you do?
`
` A. Well, the subject matter involves thermal
`
`management system of aircraft engine; that's number
`
`one. Number two, okay, fuel coking; and number
`
`three, related deoxygenation techniques. And so I
`
`did some homework before I accepted this assignment.
`
` Q. In doing that homework -- well, can you
`
`describe what you mean by "doing homework"?
`
` A. I did some literature survey. That's what
`
`I did.
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.013
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 14
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` Q. So you reviewed some literature relating
`
`to the subject matter?
`
` A. I should say this: I am reasonably
`
`familiar with this subject matter because of my
`
`research expertise and my professional activities in
`
`this general area. So what I did was, okay, I
`
`reviewed related materials, so-called literature
`
`survey. And in that regard, I reviewed reference
`
`papers and government research reports. I also did
`
`Google Scholar search in the related matters. And
`
`the purpose is, I want to make sure that I am
`
`qualified to address this matter.
`
` Q. So you mentioned the term "literature
`
`survey." Does that have a special meaning, or are
`
`you just referring to kind of looking through some of
`
`the relevant literature?
`
` A. Within the context of '392 patent.
`
` Q. So let me just make sure I understand.
`
` A. Yes.
`
` Q. When you say "within the context of '392
`
`patent," are you saying that you went and looked at
`
`literature that you thought was relevant to the
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.014
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 15
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`'392 -- the field of the '392 patent?
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` A. Yes. Relevant and related to '392
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`patents. And also the underlying technology and
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`scientific issues as described in '392 patent.
`
` Q. Did those materials that you looked at,
`
`did those help you ultimately form your opinions
`
`on -- that you expressed in your declarations
`
`submitted in this IPR?
`
` A. Oh, yes.
`
` Q. Did you -- withdraw that.
`
` Are the materials that you looked at in
`
`your investigation, are those all -- materials all
`
`cited in your declaration?
`
` A. Not all of them. But all the important
`
`and relevant materials are cited in my declaration.
`
` Q. Did any of the materials that aren't
`
`cited, did those have an impact on your ultimate
`
`opinions?
`
` MR. RASH: Objection. Form.
`
` THE WITNESS: I think this is a very broad
`
`question because my knowledge base was established
`
`pretty much based on the work that I conducted in
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`1-800-FOR-DEPO
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`GE v. UTC
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`Washington, D.C.
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`this field for more than 30 years. So the knowledge
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`base is very, very broad. And I would say, okay,
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`part of my knowledge base is applied to this
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`particular case and also described in my declaration.
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` So -- so the issue is, okay, what are the
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`specific reference materials included in my
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`declaration, I think is a little bit difficult to
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`address because of my own knowledge base and my own
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`opinion is very broad and irrelevant.
`
`BY MR. MARANDO:
`
` Q. Right. So let's set aside your knowledge
`
`base, which I'm sure is vast.
`
` A. Yes.
`
` Q. And let's set aside your knowledge base
`
`and the documents that you actually, you know, have
`
`cited --
`
` A. Yes.
`
` Q. -- in your declaration. Are there any
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`other documents that you've reviewed since first
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`being contacted by Cara that you think would -- were
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`probably relevant and had an impact on your opinion?
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` MR. RASH: Objection. Form.
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`1-800-FOR-DEPO
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`Washington, D.C.
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` THE WITNESS: I would say -- okay. I
`
`would say all the relevant materials -- relevant and
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`related materials are cited in my declaration.
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`BY MR. MARANDO:
`
` Q. So there are no other documents, setting
`
`aside your own knowledge in the field, that you
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`believe are relevant to your declaration other than
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`those cited within the declaration itself?
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` MR. RASH: Objection. Form.
`
` THE WITNESS: I think this question is a
`
`little bit broad. Let me give you a very specific
`
`example.
`
` A review paper published in the Journal of
`
`Propulsion and Power by Tim Edwards specifically
`
`addressing issues on coking, kerosene fuel coking,
`
`that review paper cited many, many reference papers.
`
`I read some of the papers cited by that review paper,
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`but I did not include those papers as cited by that
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`review paper in my declaration.
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` So in other words, I would say, okay, all
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`the relevant materials are cited in my declaration;
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`however, there are some background information cited
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`by the reference materials do not appear in my
`
`declaration.
`
`BY MR. MARANDO:
`
` Q. Sure. So after doing your initial -- I
`
`would call it a little investigation to see if you
`
`felt that you could -- or have the technical
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`expertise to work on this matter, did you ultimately
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`decide that you did and you wanted to be engaged to
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`work on the IPR?
`
` A. Yes. After I did my initial homework,
`
`so-called homework, and also related literature
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`survey, I feel confident to handle this case.
`
` Q. And you ultimately entered an engagement
`
`agreement to work on this IPR?
`
` A. Yes.
`
` Q. Do you know if that engagement is with the
`
`Finnegan firm or if it is with United Technologies?
`
` A. With our law firm, Finnegan.
`
` Q. How much are you being compensated for
`
`your time working on the IPR?
`
` A. You mean how many hours?
`
` Q. Well, I don't know the structure, so maybe
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`Washington, D.C.
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`you can explain it to me. But if it's an hourly
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`structure, how many hours and what your hourly rate
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`is. If it's some other arrangement, I'm just trying
`
`to understand what the arrangement is.
`
` A. It's based on -- the compensation is based
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`on the number of hours that I spent on this project.
`
` Q. And what's the -- what's your hourly rate?
`
` A. It's $750 per hour.
`
` Q. Is that a customary rate that you charge
`
`for your consulting work?
`
` A. Yes.
`
` Q. But this is your first -- well, let me
`
`withdraw that.
`
` Is this your first legal consulting work
`
`as far as working as a technical expert in the --
`
` A. For deposition case, this is my first
`
`time.
`
` Q. Have you worked on other types of legal
`
`proceedings as a technical expert?
`
` A. Not on legal proceedings, but I served as
`
`a technical consultant several times. And also, I
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`consulted with my colleagues in D.C. and in other
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`Washington, D.C.
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`June 28, 2017
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`places in the nation, and they suggested this is a
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`reasonable compensation rate.
`
` Q. They suggested it was a reasonable
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`compensation rate specifically for the -- this IPR
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`matter that you're being engaged for?
`
` A. For cases with a similar nature.
`
` Q. And how much time have you spent on this
`
`matter to date, if you have an estimate?
`
` A. My rough estimate up to this point is
`
`about 100 hours.
`
` Q. And that's 100 hours since -- you were
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`ultimately retained in April of 2017; is that right?
`
` A. Yes, sir.
`
` Q. And have you actually submitted your bills
`
`for this matter or are you still waiting to do that?
`
` A. I submitted my bill on a monthly basis.
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`In other words, I have already submitted my bill for
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`March -- excuse me -- April, May.
`
` Q. To date, how much compensation have you
`
`actually received for the work that you've done?
`
` A. From the inception all the way to this
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`point.
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`Washington, D.C.
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` Q. Yes.
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` A. My rough estimate is around 100 hours up
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`to this point. That includes my travel time.
`
` Q. Okay. Thanks. So that's 100 hours at
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`$750 an hour.
`
` A. Yes.
`
` Q. Okay. Let's take a look at one of the
`
`exhibits in this case that you submitted with your
`
`declaration. We don't need to remark them because
`
`they're already marked in the proceeding.
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` MR. MARANDO: This is UTC-2004. It's a
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`copy of Dr. Yang's CV.
`
` THE WITNESS: Thank you.
`
`BY MR. MARANDO:
`
` Q. You're welcome.
`
` So you can take just a look at the CV.
`
`Basically, my first question is going to be is if you
`
`recognize it and if it is, in fact, a copy of your
`
`CV.
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` A. It is my CV.
`
` Q. So UTC-2004 is a copy of your CV that you
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`submitted in connection with the declaration that you
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`1-800-FOR-DEPO
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`Washington, D.C.
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`submitted in this case, correct?
`
` A. Yes.
`
` Q. Are there any matters, since you submitted
`
`this CV, that you believe would need to be added to
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`make it accurate?
`
` A. Not for this case. I think this CV is
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`very updated.
`
` Q. There are -- so there might be some other
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`things, but you don't think they would be relevant to
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`this case; is that right?
`
` A. That's correct. For example, I gave
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`several invited talks, which -- which are not
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`included in this CV since March.
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` Q. Were those -- how many invited talks have
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`you given?
`
` A. Quite a lot.
`
` Q. Really?
`
` A. Quite a lot.
`
` Q. Were any of those at the request of either
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`Pratt & Whitney or UTC?
`
` A. No. Nothing at all.
`
` Q. So I'm just going to call out some
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`Washington, D.C.
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`June 28, 2017
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`specific pages --
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` A. Yes.
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` Q. -- that we're going to take a look at.
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`And you'll see that there are exhibit numbers
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`UTC-2004 and then .001. Those are the numbers I'm
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`going to be going by when I list page numbers.
`
` A. Sure.
`
` Q. Just starting on the page ending in .001.
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` Is this a list -- your education listed
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`here, is that an accurate summary?
`
` A. It's accurate.
`
` Q. And then your professional history also is
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`listed on that page. Is that an accurate summary of
`
`your professional history?
`
` A. Yes. It is accurate.
`
` Q. So other than your role as a process
`
`engineer at Texas Instruments in 1978, would it be
`
`accurate to say that the rest of your positions have
`
`been in the academic setting?
`
` A. Well, you may say that. But I should also
`
`point out, as a university professor, we do technical
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`consulting work for the government and industry, and
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`Washington, D.C.
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`we also provide public service.
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` For example, I'm the secretary of a
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`section of aerospace engineering of the National
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`Academy of Engineering. I also provide an advising
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`role for U.S. government; that includes NASA, Air
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`Force, and so forth.
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` So the professional history is mainly for
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`my professor's job, but that does not include other
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`important matters; for example, my -- my professional
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`service as editor-in-chief for several journals.
`
` Q. Sure. I appreciate that.
`
` A. Yes.
`
` Q. I guess what I'm just wondering is, since
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`the process engineer job at Texas Instruments, has
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`your -- following that, has your primary employment
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`been in an academic setting?
`
` A. Yes.
`
` Q. Could you take a look at the page ending
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`in 008.
`
` A. Yes.
`
` Q. So this is your professional biography; is
`
`that correct?
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` A. Yes. It's my biosketch.
`
` Q. I wanted to point -- well, you can
`
`obviously look at anything you want to on here, but
`
`I'm going to ask a specific question.
`
` There's a statement under the Research
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`heading.
`
` A. Yes.
`
` Q. And it's the last sentence there that
`
`reads, "He has been awarded more than $32.5 million
`
`to date in research funding."
`
` A. Yes.
`
` Q. Do you see that?
`
` Was any of this research funding provided
`
`by either Pratt & Whitney or United Technologies?
`
` A. As included in my -- in my CV, a very
`
`small fraction of the research funding was provided
`
`by General Electric, yes. And I can point it out to
`
`you.
`
` Q. Sorry. My question was specific to either
`
`Pratt & Whitney or United Technologies. I might have
`
`misspoke.
`
` But I'm wondering if any of the funding
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`that you're talking about here on page .008 was
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`provided by either United Technologies or Pratt &
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`Whitney.
`
` A. Not to my knowledge. But to be sure, I
`
`listed all -- all of my funded research projects on
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`page 12 all the way through page 18. That is a
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`complete summary of my funded research.
`
` Q. So if -- if there was research funded by
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`United Technologies or Pratt & Whitney, that would be
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`identified on these -- on the page ending in page
`
`.012 through --
`
` A. That's correct. If any research funded by
`
`United Technologies, that would be reflected in those
`
`pages. From page -- from page 12 all the way
`
`through page 18.
`
` Q. Sorry. One of the instructions I probably
`
`should have mentioned is sometimes I pause and I'm
`
`not quite done.
`
` A. Yes.
`
` Q. So it's just important that we try not to
`
`speak over each other. But I'll try to be better
`
`about it, too.
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` A. Thank you. You are very kind.
`
` Q. There's also on page ending in .008
`
`again --
`
` A. Yes.
`
` Q. -- also in your professional biography,
`
`there's a -- there's a statement listing companies
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`that you have consulted for.
`
` A. Yes.
`
` Q. And one of those companies is Pratt &
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`Whitney. Do you see that?
`
` A. Yes.
`
` Q. Okay. First of all, does this refer to
`
`multiple consultancies, or is it just one?
`
` A. It's a handful.
`
` Q. Is it more than -- well, you say "a
`
`handful." Is it roughly five consultancies?
`
` A. It depends on the definition of
`
`consultancy. Let me be very, very specific. I
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`did -- I did consult Pratt & Whitney some years ago.
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`If I remember correctly, that's about 20 years ago
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`for a few days. Would you consider one-day
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`consulting work a one consultancy or -- or a -- or
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`you lump them together?
`
` Q. So I would -- I would say it's always a
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`matter of degree. But if it was a discrete task that
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`you did, I would consider that a single consultancy.
`
` A. I would say no more than two.
`
` Q. Okay.
`
` A. No more than two. And the time -- the
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`time is about 15 years ago.
`
` I need to go back to be very precise. But
`
`my -- my recollection is that the most recent
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`consulting work with Pratt & Whitney was -- was about
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`15 years ago. One-five.
`
` Q. Do you have a rough estimate of how much
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`in aggregate you were paid for those consultancies?
`
` A. On the order of $10,000 in total. It's
`
`10K.
`
` Q. And you haven't consulted for Pratt up
`
`until this current proceeding for the last 15 years;
`
`is that right?
`
` A. That's correct.
`
` Q. Can you turn to the page ending in .051.
`
` A. Which page again? .51?
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`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.028
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 29
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`1
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` Q. .51.
`
` A. Yes. Sure.
`
` Q. And the heading here is Invited Talks and
`
`Seminars. Do you see that?
`
` A. Yes.
`
` Q. And I'm just going to ask about a few
`
`entries. I'll list them out and then I just have a
`
`few follow-up questions on them.
`
` A. Yes.
`
` Q. So I'll list them and then I'll tell you
`
`when I'm ready to ask and if I accurately stated what
`
`they are.
`
` A. Yes.
`
` Q. So the first entry that I wanted to ask
`
`about is No. 16.
`
` A. No. 16. Yes.
`
` Q. Numerical Methods in Combustion
`
`Instabilities.
`
` A. Yes.
`
` Q. And then it states that that is at
`
`United Technologies' Pratt & Whitney division.
`
` Do you see that?
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.029
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 30
`
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` A. Yes. Yes.
`
` Q. And then No. 25 is titled Vaporization and
`
`Combustion of Liquid-Fuel Droplets in Supercritical
`
`Environments --
`
` A. Yes.
`
` Q. -- at the United Technologies Research
`
`Center. Do you see that?
`
` A. Yes.
`
` Q. And then No. 59 is Combustion
`
`Instabilities in Liquid-Fueled Propulsion Systems at
`
`United Technologies Research Center.
`
` Do you see that?
`
` A. Yes.
`
` Q. All right. And then 63, Design
`
`Methodology for Gas Turbine Combustion Dynamics:
`
`Future Aspects at the United Technologies Research
`
`Center?
`
` A. Yes.
`
` Q. Okay. And then the last one is 104.
`
` A. 104.
`
` Q. This is Large-Eddy Simulations of Gas
`
`Turbine Combustion Instabilities, Pratt & Whitney
`
`1-800-FOR-DEPO
`
`www.aldersonreporting.com
`
`Alderson Court Reporting
`
`GE v. UTC
`IPR2016-01301
`GE-1035.030
`
`
`
`Vigor Yang, Ph.D.
`
`Washington, D.C.
`
`June 28, 2017
`
`Page 31
`
`1
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`2
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`4
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`Engines?
`
` A. Yes.
`
` Q. So the -- the entries I just listed, you
`
`would agree that those are all talks that were either
`
`given at United Technologies or Pratt & Whitney?
`
` A. There's one more which is not listed --
`
` Q. Okay.
`
` A. -- in my CV. I gave -- I gave a talk at
`
`Pratt Whitney in April this year. That -- that
`
`lecture was arranged by University of Connecticut.
`
`The background is I was invited to give a talk at
`
`University of Connecticut in April. And because of
`
`the proximity of University of Connecticut to Pratt
`
`Whitney, so University of Connecticut asked me to
`
`give the
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