BRIAN E. SPRINGETT, Ph.D.
` IN THE UNITED STATES DISTRICT COURT
` FOR THE NORTHERN DISTRICT OF GEORGIA
` ATLANTA DIVISION
`
`Page 1
`
`______________________________
`CANON, INC., )
` Plaintiff, )Civil Action No.:
`vs. )1:11-cv-03855-RLV
` )
`COLOR IMAGING, INC. and )
`GENERAL PLASTIC INDUSTRIAL )
`CO., LTD., )
` Defendants. )
`______________________________)
`
` VIDEOTAPED DEPOSITION OF:
` BRIAN E. SPRINGETT, Ph.D.
` Boulder, Colorado
` February 11, 2015
`
`Reported by: Melanie L. Giamarco, RMR CRR
`Job No.: 90188
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` IN THE UNITED STATES DISTRICT COURT
` FOR THE NORTHERN DISTRICT OF GEORGIA
` ATLANTA DIVISION
`
`Page 1
`
`______________________________
`CANON, INC., )
` Plaintiff, )Civil Action No.:
`vs. )1:11-cv-03855-RLV
` )
`COLOR IMAGING, INC. and )
`GENERAL PLASTIC INDUSTRIAL )
`CO., LTD., )
` Defendants. )
`______________________________)
`
` VIDEOTAPED DEPOSITION OF:
` BRIAN E. SPRINGETT, Ph.D.
` Boulder, Colorado
` February 11, 2015
`
`Reported by: Melanie L. Giamarco, RMR CRR
`Job No.: 90188
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` BRIAN E. SPRINGETT, Ph.D.
` February 11, 2015
` 9:02 a.m.
`
` VIDEOTAPED DEPOSITION OF BRIAN E. SPRINGETT,
`Ph.D., taken by the Plaintiff at the offices of
`Faegre, Baker & Daniels, 1470 Walnut Street,
`Boulder, Colorado, before Melanie L. Giamarco, a
`Registered Professional Reporter, Registered Merit
`Reporter, Certified Realtime Reporter and Notary
`Public of the State of Colorado.
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` BRIAN E. SPRINGETT, Ph.D.
`APPEARANCES:
` FITZPATRICK CELLA HARPER & SCINTO
` Attorneys for the Plaintiff
` By: Peter Shapiro Esq.
` 1290 Avenue of the Americas
` New York, NY 10104
`
` FITZPATRICK CELLA HARPER & SCINTO
` Attorneys for the Plaintiff
` By: Chitra Kalyanaraman Esq.
` 975 F Street Northwest
` Washington, DC 20004
`
` MORRIS MANNING & MARTIN
` Attorneys for the Defendants
` By: John Fry Esq.
` 3343 Peachtree Road Northeast
` Atlanta, GA 30326
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` BRIAN E. SPRINGETT, Ph.D.
` I N D E X
`BRIAN E. SPRINGETT, Ph.D. PAGE
`By Mr. Shapiro 7, 236
`By Mr. Fry 223
` E X H I B I T S
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1 Expert Report of Dr. B. E. 62
` Springett Regarding Invalidity
` of United States Patent No.
` 7,647,012
`Exhibit 2 United States Patent No. 110
` 7,647,012
`Exhibit 3 Expert Report of Dr. B. E. 111
` Springett Regarding
` Non-Infringement of United
` States Patent No. 7,647,012 in
` Response to the Initial Expert
` Report of Robert H. Sturges,
` Jr., Ph.D.
`Exhibit 4 Expert Report of Dr. B. E. 112
` Springett on the Technological
` Value of the '012 Patent in
` Response to the Expert Report
` of Michael E. Tate
`Exhibit 5 Rebuttal Expert Report of 113
` Dr. B.E. Springett Regarding
` Invalidity of United States
` Patent No. 7,647,012
`*Exhibit 6 Updated Joint Stipulation 118
` Between the Parties Regarding
` Representative Accused Toner
` Bottle Products
`
`*Original exhibit retained by Ms. Kalyanaraman
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` BRIAN E. SPRINGETT, Ph.D.
` E X H I B I T S (CONTINUED)
`EXHIBIT DESCRIPTION PAGE
`Exhibit 7 Updated Joint Stipulation 125
` Between the Parties Regarding
` Representative Accused Toner
` Bottle Products
`Exhibit 8 United States Patent 149
` Application Publication No.
` 2002/0044795 A1
`Exhibit 9 United States Patent No. 150
` 6,698,966
`Exhibit 10 United States Patent No. 150
` 6,501,990
`Exhibit 11 United States Patent No. 151
` 5,218,407
`Exhibit 12 United States Patent No. 151
` 5,765,079
`Exhibit 13 United States Patent No. 152
` 5,903,806
`Exhibit 14 United States Patent No. 152
` 5,966,574
`Exhibit 15 United States Patent No. 153
` 6,298,208
`Exhibit 16 United States Patent No. 153
` 6,412,163
`Exhibit 17 Special Master's Claims 240
` Construction Report and
` Recommendations
`Exhibit 18 Special Master's Claims 239
` Construction Report and
` Recommendations
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` BRIAN E. SPRINGETT, Ph.D.
` P R O C E E D I N G S
` VIDEOGRAPHER: This is the start of tape
`labeled Number 1 of the videotaped deposition of
`Brian Springett in the matter of Canon, Inc. versus
`Color Imaging, Inc., et al., in the United States
`District Court for the Northern District of
`Georgia, Atlanta Division, Case Number
`1:11-CV-03855-RLV. This deposition is being held
`at 1470 Walnut Street, Boulder, Colorado, on
`February 11th, 2015, at 9:02 a.m. My name is Davis
`Baumunk, and I am the legal-video specialist from
`TSG Reporting, Inc., headquartered at 747 Third
`Avenue, New York, New York. The court reporter is
`Melanie Giamarco, in association with TSG
`Reporting.
` Counsel, will you please introduce
`yourselves.
` MR. SHAPIRO: Peter Shapiro from
`Fitzpatrick, Cella, Harper & Scinto, for Canon.
`And with me from my office is Attorney Chitra
`Kalyanaraman.
` MR. FRY: John Fry with Morris, Manning &
`Martin, for the defendants.
`//
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` BRIAN E. SPRINGETT, Ph.D.
` BRIAN E. SPRINGETT, Ph.D.,
`after having been duly sworn, was examined and
`testified as follows:
` EXAMINATION
`BY MR. SHAPIRO:
` Q. Good morning, Dr. Springett.
` A. Hello again.
` Q. For the record, could you please state
`your full name and address.
` A. My full name is Brian Edward Springett.
`I live, currently, at 4620 Boulder -- Chestnut
`Avenue, Boulder, Colorado 80301.
` Q. Do you understand today, sir, that
`you're testifying under oath subject to the penalty
`of perjury?
` A. Yes, I do.
` Q. And I'm going to ask you to consider a
`few ground rules for today's deposition.
` A. Okay.
` Q. If you don't understand a question at
`any time, please let me know, and I'll try to
`clarify it for you. Is that okay?
` A. Sure.
` Q. If you do answer a question, I'll assume
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`that you understood it.
` A. Okay.
` Q. If you need a break at any time, let me
`know. And the only thing I would ask is that you
`answer pending questions before asking for a break.
`Is that okay?
` A. Sure.
` Q. And I'll try to accommodate any breaks
`you want.
` A. Yeah.
` Q. Is there any reason you can't give
`truthful and accurate testimony today?
` A. No.
` Q. Okay. Great. And your attorney may
`object to my questions from time to time, but
`unless he instructs you -- specifically instructs
`you not to answer the question, you're still
`obligated to answer the question, okay?
` A. Okay.
` Q. Please describe your educational
`background.
` A. Starting at what age?
` Q. Starting from college.
` A. I went to the University of Cambridge,
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` BRIAN E. SPRINGETT, Ph.D.
`Downing College. I started there in 1957 and
`graduated with a bachelor's degree -- Bachelor of
`Arts from Cambridge. And the topics I studied were
`physics and mathematics. But that also includes a
`few subsidiary topics, like chemistry and geology.
` After that, I came to the United States to
`work for a semiconductor company in California,
`which I did for a year. And then I went to the
`University of Chicago in the graduate program in
`the physics department where I stayed until 1967,
`graduating from there with a Ph.D. in physics. The
`subjects I studied there were solid-state physics,
`semiconductor physics and low-temperature physics.
` After that, I spent one year in that process
`as a post-doc at Chicago. Then after that, I went
`to the University of Michigan. And at that point,
`I guess my educational career ended, unless you
`count the fact that I was teaching at the
`University of Michigan in the physics department
`for several years.
` Q. At some point, did you also get a
`Master's of Physics from Cambridge?
` A. Yeah, that is -- it's an MA, and there's
`some sort of a pro forma affair. You basically
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` BRIAN E. SPRINGETT, Ph.D.
`have to stay out of trouble and be gainfully
`employed in your nominal graduate-degree
`profession, and then you get a master's degree.
` Q. So just --
` A. It's really straightforward. On the
`other hand, I did get a master's -- excuse me.
` I did get a master's degree at the
`University of Chicago, which is a step toward
`getting the Ph.D. there.
` Q. Right. Now, in your undergraduate
`studies, you majored in physics and mathematics,
`you said --
` A. Yes.
` Q. -- right?
` A. Yes.
` Q. As part of your course study in physics,
`did you take a course in mechanics?
` A. Yeah.
` Q. Just the standard mechanics with trusses
`and the like?
` A. More -- more to do with materials than
`the forces applied in beams and that sort of thing.
` Q. Okay.
` A. But when one's talking about materials,
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`because there's a physics bent, you're talking
`about the properties of the materials as they are
`applied in a mechanical engineering sense.
` Q. So you studied the characteristics of
`the materials themselves?
` A. Yeah, as well as how they're joined
`together and all those sorts of things. Plus the
`usual stuff, pullies and levers and all that sort
`of thing.
` Q. Right. That was at -- would you
`characterize that as sort of the basic physics
`mechanics -- undergraduate mechanics course?
` A. Yeah. Yeah.
` Q. Did you take any other mechanics courses
`as an undergraduate?
` A. I'm trying to divine what you mean by
`"mechanics" here.
` Q. Courses that dealt with either the
`mechanic -- the physics of mechanics or mechanical
`engineering.
` A. Other than that they were kind of wedded
`in with the other physics courses, no course that
`was titled that, no.
` Q. Okay. And how about in your graduate
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`study -- what was the focus of your graduate
`studies?
` A. It was a study of charged particles in
`liquid helium with an aim to try to understand the
`fluid mechanics of liquid helium. Along the way,
`this involved some interaction with just regular
`fluid mechanics, the sorts of things you find in,
`say, a textbook by Chandrasekhar, for example, who
`we did some experimental work for to back up his
`theories.
` Q. Would you characterize that as
`solid-state physics?
` A. Well, it was liquid, so it's not solid
`state, but it was physics.
` Q. I guess, solid-in-liquid-state physics.
` A. Well, I guess the difference is, one
`flows and the other sort of sits there.
` Q. Right. So typically, in some of my
`cases, I have solid-state chemists that study the
`changes of states in chemistry. Is that similar to
`the type of work that you were studying, but with a
`physics bent?
` A. We were talking about -- that's a phase
`transition, and yes, we certainly did study phase
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`transitions. Liquid helium goes through one as a
`liquid, in fact.
` Q. How did your concentration differ from
`what, you know, we typically think of as a
`solid-state chemist?
` A. Let me back up a little bit. When I
`went to California, I worked for a semiconductor
`company, and that is true solid-state physics.
`That is the behavior of charged particles inside
`various kinds of materials in the context of a
`structure, which is crystalline mostly. In the
`case of the fluid, there is no structure that's
`easily determined of the fluid, and so the linkage
`is how the charged particles are behaving within
`the material.
` Q. Okay. What was that company, the name
`of that --
` A. It's called Hoffman Semiconductor.
` Q. So this is when you first came to the
`U.S.?
` A. Yes, it is -- was.
` Q. And you worked there for one year?
` A. I was there for one year, yes.
` Q. And what did you do there?
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` A. I did two things there. One -- in
`general, that is. One was working on the process
`of diffusing minor elements into silicon, a little
`bit of germanium, but mostly silicon. That means
`designing furnaces and the lots of glassware and
`lots of tubing to pump gases containing these
`elements around. The other aspect of that was
`actually measuring the devices once they'd been
`made. So it's evolved all the way from just
`looking at the parameters, making sure they were
`within specification, that sort of thing, in some
`cases designing the electrical circuitry to do
`that.
` The other thing that I did there as a part
`of my work, because we were talking about the
`furnaces just prior to that, was involved with not
`so much designing in my case, but producing solar
`cells.
` Q. So when you say measuring the devices
`once they've been made, can you elaborate on that a
`little bit? What did you do, specifically?
` A. These were transistors. And a
`transistor typically has three electrodes. So you
`end up with this little device with three prongs,
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`and it gets plugged into a circuit. And then what
`you're trying to do is to measure those parameters
`that have to do with how the transistor, for
`example, would amplify signal, what its noise level
`was when it's in a quiescent state, things of this
`kind.
` Q. And did you -- and part of your graduate
`studies, did you take any courses that related to
`the physics of mechanical devices, mechanical
`interactions or devices, anything like that?
` A. That's a difficult question to answer.
`In terms of academic work, pure academic work, the
`answer is no. But as part of the Ph.D. program,
`you have to -- formal program, that is, as opposed
`to the research, you had to take a lab course,
`which included various kinds of experiments that
`were things like using x-rays or -- let's see. My
`memory's failing me as to what other particular
`ones, but anyway, the point I was going to get to
`was that part of this was a machine-shop
`experience. So you had to make things on lathes
`and milling machines and so forth.
` Q. And to the -- I know this was a long
`time ago, and this is a minor aspect of your study,
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`but to the best of your memory, can you tell me
`what types of things you did with respect to that?
` A. I made a screwdriver.
` Q. Okay.
` A. Of three -- three different metals put
`together. I made a -- sort of a cup, basically,
`out of -- I forget what kind of plastic it was. It
`was white, anyway. Basically, you started off with
`a cylinder, you cut the cylinder. You bore out a
`hole, then you bore out a different hole, and you
`put one over the other, just like that.
` Q. To make a cup?
` A. Yes. And this was to get you used to
`working with different materials, like metals and
`plastics, and the machinery. Because when you
`started on your own research, you were --
`experimental research, that is, you were inevitably
`going to be making things as part of the
`experimentation that you embarked on.
` Q. So this was to train you, basically, to
`use the machines that you would use to make your
`semiconductor devices, is --
` A. No, no, no. This would be to train you,
`for example, working with liquid helium, a certain
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` BRIAN E. SPRINGETT, Ph.D.
`amount of it is straight plumbing. You're putting
`pipes together, so you had to learn how to -- how
`to put one pipe into a joint and weld it.
` Q. To do your experiments with the helium?
` A. Yeah. Yeah.
` Q. Okay. And so the screwdriver, you said,
`had three metals.
` Were you studying the metal properties in
`the screwdriver, or this was just practice to
`create a screwdriver?
` A. This was to understand that when you
`have different metals and you're using a lathe, in
`this particular case I think it was, they behave
`differently. So, for example, when you have a
`piece of machine tool and you want to take off a
`layer, the amount you take off per parse on brass
`is different than on steel. It's different on
`aluminum. The speed in which you do it is
`different because of the properties of the metal.
`That's the kind of thing we were . . .
` Q. Okay. And similarly, working with
`plastic has its own set of properties?
` A. Right. Right.
` Q. Are you currently employed?
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` A. Again, that's a difficult question to
`answer in a very specific way. My current
`employment is working as a consultant on one case,
`which this is.
` Q. Okay. Are you -- do you have a company
`that you have -- that you have agreements on behalf
`of? Or you just personally signed an agreement to
`work on this case?
` A. I personally signed an agreement. In
`this particular case, though, there was an
`intermediary company called IMS.
` Q. IMS, the data-service company, or a
`different IMS?
` A. I don't know the answer to that
`question. IMS Expert Services.
` Q. Okay. IMS Expert Services. And is it,
`like, a service? You give them your resume, or
`something like that, and they contact you?
` A. Yes. They approached me, yes.
` Q. So, like, you signed up with this
`service at some point in the past, I guess, and
`gave them --
` A. No, no, no. It was unique to this
`instance.
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` BRIAN E. SPRINGETT, Ph.D.
` Q. They just found you?
` A. Yes.
` Q. And what is Fingerpost Advisers?
` A. That's the name I operate under as an
`independent consultant.
` Q. Is that an incorporated entity or a
`partnership, or something?
` A. It's a registered entity, New York
`State.
` Q. So that's, like, your own consulting
`company?
` A. Yes.
` Q. Do you -- when you sign your contracts,
`do you do it on behalf of Fingerpost Advisers or in
`your personal name?
` A. I do it as Brian Springett, Fingerpost
`Advisers.
` Q. Okay. So as a representative of
`Fingerpost Advisers?
` A. Yes.
` Q. And what kind of -- right now, this is
`the only consulting job that Finger -- that
`Fingerpost Advisers has --
` A. Correct.
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` BRIAN E. SPRINGETT, Ph.D.
` Q. -- is that correct?
` But in the past, you've done other
`consulting work?
` A. Yes.
` Q. So what -- can you describe to me the
`other types of -- I guess type categories of the
`types of consulting work you've done as part of
`fingerpoint advisers -- Fingerpost Advisers?
` A. Okay. Let's do it as categories.
`Giving educational kinds of talks at various
`conferences, meetings, seminars on the subject, the
`broad subject and the subparts of it, of
`electrophotography; engaging with companies who
`have very specific problems related to their
`current activities involving electrophotography;
`engaging with companies who wish to get into the
`business of selling electrophotographic products,
`which includes, of course, designing them from the
`ground up; engaging with companies in a similar
`manner who wish to get involved in some aspect of
`electrophotography; producing materials of various
`kinds, for example.
` There have been a miscellany of outliars, a
`fuel-cell company. This had to do with the
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` BRIAN E. SPRINGETT, Ph.D.
`materials of the fuel cell. A company that wanted
`to figure out whether or not leftover stuff from
`iron processing could be used in the
`electrophotographic business.
` I guess another category would be specific
`requests for educating sets of employees -- so this
`I did with three, maybe four companies -- across
`the broad spectrum of electrophotography as a
`business, as a commercial enterprise.
` Q. Does that differ -- your first category
`was educational-type talks on --
` A. This is -- this is public. The other is
`private.
` Q. Okay. Anything else that you can think
`of?
` A. Those are the broad categories, yeah.
` Q. And it's just you at Fingerpost
`Advisers, right? You don't have other employees?
` A. It's me unless I suggest that someone
`else be brought on board, but not working for me,
`so it would be a parallel operation in that case.
` Q. Does that happen a lot?
` A. I think it's happened twice.
` Q. Under what circumstances?
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` BRIAN E. SPRINGETT, Ph.D.
` A. One circumstance was that the amount of
`highly detailed information required was a bit
`beyond my capability.
` Q. What was the subject matter?
` A. This was to do with -- now we're getting
`into proprietary areas.
` Q. Yeah, I mean, just broadly, the subject.
` A. This had to do with toner itself, the
`material itself.
` Q. The toner material, like, the powdery
`substance?
` A. Yes, yes.
` Q. And you would consider yourself an
`expert on toner materials itself, right?
` A. Yeah. Yeah.
` Q. But there was some aspect that was
`beyond your expertise?
` A. This had to do with the whole history of
`the patent aspect of it, and -- this is, as I say,
`it gets a bit proprietary. It had to do with other
`companies.
` Q. Okay. I mean, I don't want you to --
` A. And competitive situations and this sort
`of thing.
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` BRIAN E. SPRINGETT, Ph.D.
` Q. I don't want you to reveal detailed
`confidential information --
` A. I understand.
` Q. -- but I just want to sort of understand
`what aspect of expertise you needed help on on that
`case. Like, you had to bring someone else in.
` A. It had to do with the fact that we were
`analyzing a lot of other companies' capabilities.
` Q. Okay. So somebody else came in who
`was -- sort of knew the industry better; is that --
` A. No, not better, just some aspects of
`it --
` Q. That you didn't know?
` A. -- that were more pertinent and
`immediately known to them that I would have had to
`go digging for, yes.
` Q. So it wasn't a technical subject matter
`that they knew more about?
` A. No. No, no. No. No, it had to do with
`company capabilities. That's why I say it's . . .
` Q. Yeah, I mean, can you -- without
`revealing confidence, can you say what the
`capability is that this person knew more about as
`sort of a general topic?
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` BRIAN E. SPRINGETT, Ph.D.
` A. Things like production capabilities.
` Q. How these things were manufactured?
` A. No, no, no. How much was being made,
`where it was being made, what it cost, that sort of
`thing.
` Q. Okay. Anything else?
` A. No, no, that -- it's business-type
`information related to toner.
` Q. And then the other time you brought
`somebody else in, what was -- what were the
`circumstances?
` A. Oh, that was associated with the
`fuel-cell business. What they were concerned with
`was whether or not they had a business process
`internal to the company that one would consider
`close to being benchmark. I know something about
`that, but they needed guidance, so I suggested
`someone they could talk to about that.
` Q. So fuel-cell technology isn't your
`primary area of expertise?
` A. No, no, it was the materials aspect of
`it. Yeah.
` Q. Okay. So you brought someone else in
`who was more of a fuel-cell expert, in general?
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` BRIAN E. SPRINGETT, Ph.D.
` A. No, no, no, nothing to do with -- no,
`no, this is business process, right, you know?
` Q. Oh, business process.
` A. Any company has its internal workings
`that can be more or less efficient. And there's a
`whole wealth of literature on the subject. And
`this company was concerned that their business
`process in that context was not up to snuff, and
`they needed some guidance as to how to do that.
` Q. So this person was, like, an
`internal-process person; is that fair to say?
` A. Well, someone who knew about how to
`conduct brainstorming sessions inside a company,
`how to start examining a process so that your
`quality-control systems were not missing anything,
`so that you were able to have fewer errors along
`the whole steps in making a fuel cell. You didn't
`have to know anything about fuel cells to implement
`or talk about that kind of thing.
` Q. Now, you worked at Xerox, I guess, for
`many years, right?
` A. Yeah, twenty-plus. I can't remember the
`precise number anymore.
` Q. So we'll talk about Xerox, but were
`
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` BRIAN E. SPRINGETT, Ph.D.
`there any other places aside from Xerox that we
`haven't already talked about where you -- where you
`worked?
` A. University of Michigan.
` Q. Okay. What was your job there?
` A. Assistant professor in the physics
`department.
` Q. And what did you do?
` A. I taught physics.
` Q. Standard physics? Graduate-level?
` A. Both. I had a couple of graduate
`students.
` Q. And the -- so undergraduate was just,
`like, Physics I, II, that kind of thing, that you
`taught?
` A. I forget what the numbers of the courses
`were, but I taught all four years, you know,
`juniors -- seniors back through freshmen, yes.
` Q. Okay. And did you teach any courses in
`mechanics?
` A. Yes. The way the University of Michigan
`was structured, it had several schools. The
`physics department is located in the School of -- I
`believe it's called Arts and Sciences. But anyway,
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` BRIAN E. SPRINGETT, Ph.D.
`they also had a School of Architecture, of
`Education, I think, and an engineering school. The
`engineering school did not have separate physics
`teachers. All of the engineering students came to
`the physics department, and the chemistry
`department and so forth, and so one taught physics,
`recognizing that you were teaching engineers.
` Q. Right. And when you taught that --
` A. So there were elementary courses in
`basically mechanics and elementary courses in
`electricity and magnetism at the first two years.
`After the first two years, the engineers more or
`less vanished from the scene of the physics
`department.
` Q. So when you taught, I guess, the
`engineering students along with the physics
`students in the same class -- right? Is that . . .
` A. They tended to be mixed, but there were
`far more engineering students than there were
`physics students.
` Q. Sure. And was that sort of a general
`physics course where you taught Maxwell's
`equations, you taught a section on mechanics and
`the like?
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` BRIAN E. SPRINGETT, Ph.D.
` A. Yeah. Yeah.
` Q. So it's sort of like what we would
`typically call, like, Physics I and II at a
`university?
` A. Yeah, as well as any of the engineers
`students who wanted to come to the second- and
`third-year courses as well.
` Q. Right, if they elected to.
` A. But that was elective, yeah.
` Q. Did you teach a course specifically just
`with regard -- like, I -- I'm an electrical
`engineer. I took a physics course called
`Mechanics. It was after I took Physics I and II.
`It was a separate course. It talked about, like,
`trusses and bridges and things like that. Did you
`teach that course?
` A. I did not teach that course.
` Q. And did you teach any other more
`advanced courses that were specifically related to
`mechanics?
` A. Solid-state physics, the properties of
`materials, and statistics.
` Q. And your -- you said you had a few
`graduate students that --
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` BRIAN E. SPRINGETT, Ph.D.
` A. Two.
` Q. Two? And were you their advisor?
` A. Yes.
` Q. What were their -- do you recall what
`their sub -- their topics were?
` A. One of them was to do with, again,
`charged particles in helium. Both of them started
`that way. One of them moved on to basically
`ejecting the charged particles out of the liquid
`into the gas above it. The other one switched to
`looking at charged particles in liquid neon and
`liquid hydrogen.
` Q. Did they get their Ph.D.s?
` A. Yes.
` Q. Under you? Or did they --
` A. Yes. Yes. At the University of
`Michigan, yeah.
` Q. So let's talk about your experience at
`Xerox.
` A. Okay.
` Q. Why don't you tell me about what you did
`there when you started there.
` A. When I started there, I worked in a
`group that was concerned with the process by which
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` BRIAN E. SPRINGETT, Ph.D.
`the photoconductor was charged.
` Let me ask a question. May I?
` Q. Sure.
` A. How familiar are you with the
`electrophotographic process?
` Q. Not super familiar, so if you could
`explain anything that wouldn't be obvious to,
`maybe, a layperson, that would be good.
` A. Okay. By "charging the photoconductor,"
`I mean the photoconductor is a solid-state device
`that's light sensitive, and you layer -- put a
`layer of charge on top of it, and then you modulate
`that to create an electrostatic image.
` Q. Okay.
` A. So that's what I did first. And
`basically,
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