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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` * * *
`
`REACTIVE SURFACES LTD., LLP,
` Petitioner,
`
` vs. CASE: IPR2016-01914
`
`TOYOTA MOTOR CORPORATION,
` Patent Owner.
` * * *
`
` Videotaped Deposition of
`JONATHAN S. DORDICK, PhD, a witness herein,
`called by the petitioner for examination
`pursuant to the Rules of Civil Procedure, taken
`before me, Patti Stachler, RMR, CRR, a Notary
`Public within and for the State of Ohio, at the
`Offices of Dinsmore & Shohl, LLP, 255 East
`Fifth Street, Suite 1900, Cincinnati, Ohio, on
`October 18, 2017, at 9:49 a.m.
` * * *
`
`Worldwide Court Reporters, Inc.
`(800) 745-1101
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`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` * * *
`
`REACTIVE SURFACES LTD., LLP,
` Petitioner,
`
` vs. CASE: IPR2016-01914
`
`TOYOTA MOTOR CORPORATION,
` Patent Owner.
` * * *
`
` Videotaped Deposition of
`JONATHAN S. DORDICK, PhD, a witness herein,
`called by the petitioner for examination
`pursuant to the Rules of Civil Procedure, taken
`before me, Patti Stachler, RMR, CRR, a Notary
`Public within and for the State of Ohio, at the
`Offices of Dinsmore & Shohl, LLP, 255 East
`Fifth Street, Suite 1900, Cincinnati, Ohio, on
`October 18, 2017, at 9:49 a.m.
` * * *
`
`Worldwide Court Reporters, Inc.
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` I N D E X
`
`JONATHAN S. DORDICK, PhD PAGE
` EXAMINATION BY MR. FASSOLD 4
`
`EXHIBITS REFERENCED
` EXHIBIT 1001 15
` US Patent '618
`
` EXHIBIT 1005 49
` US Patent '720
` EXHIBIT 1011 23
` Office communication from
` US Patent and Trademark Office
` 6/21/10
`
` EXHIBIT 1012 16
` Amendment in Response to
` Non-Final Office Action
`
` EXHIBIT 1013 24
` Chemical characterization of
` fingerprints from adults and
` children
` EXHIBIT 2010 5
` Declaration of
` Jonathan Dordick, PhD
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`APPEARANCES:
` On behalf of the Petitioner:
` Watts Guerra, LLP
` By: Mark A. J. Fassold, Esq.
` and
` David O. Simmons, Esq.
` 4 Dominion Drive
` Building 3
` Suite 100
` San Antonio, Texas 78257
` 210.447.0500
` mfassold@wattsguerra.com
` dsimmons@wattsguerra.com
`
` On behalf of the Patent Owner:
` Dinsmore & Shohl, LLP
` By: John D. Luken, Esq.
` and
` Oleg Khariton, Esq.
` 1900 First Financial Center
` 255 East Fifth Street
` Cincinnati, Ohio 45202
` 513.977.8200
` john.luken@dinsmore.com
` oleg.khariton@dinsmore.com
`
` Also present:
` Steve Troncone, Videographer
` Jonathan D. Hurt, Esq.
` (via telephone)
` Rico Reyes, Esq.
` (via telephone)
` * * *
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` THE VIDEOGRAPHER: We are now on
`the video record. Today is October 18th, 2017.
`The time is approximately 9:49 a.m.
` We're here today in the matter of
`Reactive Surfaces, LLP versus Toyota Motor
`Corporation, Case Number IPR2016-01914. We're
`here to take the deposition of Jonathan
`Dordick, PhD.
` Will you please raise your right
`hand to be sworn by the court reporter?
` JONATHAN S. DORDICK, PhD
`a witness herein, having been first duly sworn
`as hereinafter certified, was examined and
`deposed as follows:
` EXAMINATION
`BY MR. FASSOLD:
` Q. Dr. Dordick, if you would, please
`state your full name for the record.
` A. Jonathan Seth Dordick.
` Q. And where do you work?
` A. I work at Rensselear Polytechnic
`Institute.
` Q. And you are here today on behalf
`of whom?
` A. On behalf of Toyota.
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` Q. You've been hired by Toyota's
`counsel to provide opinions in this matter; is
`that correct?
` A. That's correct.
` Q. I'd like to show you what's been
`marked as Toyota Exhibit 2010. Do you
`recognize that document?
` A. Yes.
` Q. What is it?
` A. It's my declaration.
` Q. When was the last time you
`reviewed it?
` A. Yesterday; went over what I had
`written from a couple months ago.
` Q. Okay. And is it fair to say that
`you reviewed all 118 pages, or whatever it is?
` A. Well, I reviewed the declaration
`part. I didn't review my CV.
` Q. Do you want to make any changes to
`that declaration?
` A. There may have been a few
`misspellings here and there, but I don't think
`it's significant.
` Q. As you sit here today, do you want
`to change any of the opinions that you
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`announced in that declaration?
` A. I do not.
` Q. Okay. If you would, please turn
`to page 22, and I'd like you to look at
`paragraph 34. Go ahead and take a minute to
`read that paragraph, if you would, to yourself.
` A. Okay.
` MR. HURT: Good morning. John
`Hurt here.
` MR. FASSOLD: Hey, John, we have
`already started the deposition.
`BY MR. FASSOLD:
` Q. Okay. Dr. Dordick -- Dr. Dordick,
`you see where in the first sentence you say,
`The institution decision further recognized
`that petitioner relies solely on the
`statement -- statements of Dr. Rozzell to show
`that lipase facilitates the vaporization of
`fingerprints inherently when the fingerprints
`are, quote, in a environment that would support
`such vaporization such as an ambient
`environment consistent of air.
` Do you see that?
` A. Yes.
` Q. Does Buchanan show that a lipase
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`facilitates the vaporization of fingerprints?
` A. No, she doesn't.
` Q. Does the '618 patent show that
`lipase facilitates the vaporization of
`fingerprints inherently when the fingerprints
`are in an environment that would support such
`vaporization?
` A. Yes.
` Q. Okay. Why is it that you believe
`that Buchanan does not show that a lipase
`facilitates the vaporization of fingerprints?
` A. Well, so Buchanan doesn't actually
`describe any use of enzymes, so no lipases, for
`example. She actually doesn't even discuss or
`show, I should say, fingerprints. She's
`looking at simply components.
` Q. As you used the term vaporization
`there in paragraph 34, that first sentence,
`what's your definition of vaporization?
` A. Effectively evaporation. So
`components that have a measurable vapor
`pressure would tend to evaporate over time.
` Q. Is there any distinction that you
`draw between vaporization and evaporation?
` A. They're basically synonyms.
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` Q. Is there any distinction at all?
` A. No.
` Q. Again, in that first sentence of
`paragraph 34 you use the term facilitates.
` Do you see that?
` A. Yes.
` Q. What's your definition of the word
`facilitates?
` A. It means to aid. And so in the
`case of an enzyme, enzymes facilitate chemical
`reactions by accelerating them. So effectively
`they're aiding them, they're facilitating them.
` Q. Is there any other meaning that
`you ascribe to the word facilitates other than
`meaning to aid?
` A. No.
` Q. What is the distinction between
`facilitating and enabling?
` A. Facilitating --
` MR. LUKEN: Objection.
` You can answer.
` THE WITNESS: Okay.
` A. Well, facilitating is exactly what
`I had indicated. So when I say a lipase
`facilitates, when a lipase catalyzes a
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`reaction, it facilitates that chemical
`reaction.
` In the case of enabling, I think
`enabling has a requirement that the lipase has
`the ability to do exactly that or an entity has
`the ability to do something that you're
`ascribing.
`BY MR. FASSOLD:
` Q. Do you draw any other distinction
`between facilitating and enabling?
` A. Not really, no.
` Q. If you go to the next page,
`paragraph 35, go ahead and read it to yourself,
`on fingerprints.
` A. Okay.
` Q. That next-to-last sentence you say
`that, The particular problem that concerned the
`inventors of the '618 patent was the removal of
`fingerprints that are visually apparent to the
`naked eye from the surface.
` Do you see that?
` A. Yes.
` Q. Does a lipase aid the removal of
`fingerprints that are visually apparent to the
`naked eye from a surface?
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` A. Well, according to the '618
`patent, it does.
` Q. And, therefore, if you -- again,
`you said facilitates means to aid, correct?
` A. That's correct.
` Q. And so then you also agree that a
`lipase facilitates the removal of fingerprints
`that are visually apparent to the naked eye
`from a surface?
` A. I agree with that.
` Q. Okay. Again, if we go to
`paragraph -- the last sentence of paragraph 42.
` A. Okay.
` Q. You say, I am aware of any prior
`art reference that discloses the active removal
`of a fingerprint stain or other bioorganic
`stain from a surface based on the catalytic
`action of lipase to facilitate the removal of
`the stain by vaporization.
` MR. LUKEN: I think you said aware,
`and the document says unaware.
` MR. FASSOLD: If I did, I apologize.
`BY MR. FASSOLD:
` Q. Do you see where I read that?
` A. Yeah.
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` Q. Okay. Are you at this time still
`unaware of any prior art reference that
`discloses such active removal of a fingerprint
`or other bioorganic stain?
` A. Yes. In terms of the actual full
`sentence, there's several components.
`Fingerprint, I'm fully unaware that there's a
`prior art document that describes that. And in
`terms of the lipase facilitating removal of a
`stain as defined by the '618 patent, which is
`broader than just fingerprints, I do not know
`of any prior art reference where the lipase
`facilitates its removal as of -- due to the
`process of vaporization.
` Q. Does the '618 patent disclose the
`active removal of a fingerprint stain or other
`bioorganic stain from a surface based on the
`catalytic --
` MR. REYES: Rico here.
`BY MR. FASSOLD:
` Q. -- based on the catalytic action
`of lipase to facilitate the removal of the
`stain by vaporization?
` A. Can you repeat that? Because
`there was interference with the phone.
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` Q. Does the '618 patent disclose the
`active removal of a fingerprint stain or other
`bioorganic stain from a surface based on the
`catalytic action of lipase to facilitate the
`removal of the stain by vaporization?
` A. Yes, I believe it does.
` Q. I'm going to change it a little
`bit from active to passive.
` A. Okay.
` Q. Does the '618 patent disclose the
`passive removal of a fingerprint stain or other
`bioorganic stain from a surface based on the
`catalytic action of lipase to facilitate the
`removal of the stain by vaporization?
` A. I'm not quite sure what the term
`passive has to do with an enzyme reaction.
` Q. Let me ask you this. You see
`where you use the term active removal?
` A. Yes.
` Q. What do you mean by active
`removal?
` A. So active removal is that -- with
`an enzyme you have the catalytic activity that
`causes an event, causes a reaction. That
`reaction can be, for example, removal of a
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`fingerprint stain. So the ability of an enzyme
`to function is an active function of that
`enzyme. The passive aspect would indicate that
`just the presence of the lipase, even if it was
`inactivated, would be able to do that.
` Q. And, therefore, the mere presence
`of a lipase, especially when it has not been
`activated, does not cause -- would not cause
`the removal of a fingerprint stain?
` A. So a lipase is already active. If
`you were to physically inactivate, so you could
`heat it to a very high temperature, let's say,
`in an aqueous solution, then put it into a
`paint or coating, do a simple measurement, show
`that it has no activity, that would then be
`used in a control. There are several types of
`controls.
` And so in this particular case,
`that was not done. So I would not expect a
`lipase that was an active lipase to be able to
`do anything passive. Just the presence of the
`enzyme protein itself is not sufficient.
` Q. Okay. Is it correct to say that
`you just said, I would not expect a lipase that
`was an active lipase to be able to do anything
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`passive?
` A. Yeah. Effectively what I said
`was, if you put a -- an inactive enzyme, so
`just a protein that was not active, so it could
`come from a lipase that was inactivated so it
`has no lipolytic activity whatsoever, I would
`not expect that protein to facilitate the
`removal of fingerprint.
` Q. Going back to your statement on
`page 29 of your declaration, again, you make
`reference to, quote/unquote, active removal,
`and you've given us your definition of that.
`What does passive removal mean?
` A. Passive removal would be that, for
`example, in the absence of an enzyme, you can
`have the removal of a stain in a period of time
`that would be similar to what would happen with
`the enzyme.
` MR. FASSOLD: Can we go off the
`record?
` THE VIDEOGRAPHER: Off the record at
`10:05.
` (Off the record.)
` THE VIDEOGRAPHER: We're back on the
`record at 10:06.
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`BY MR. FASSOLD:
` Q. Dr. Dordick, I'd like to show you
`what's been marked as Exhibit 1001. Do you
`recognize that document?
` A. Yes, I do.
` Q. What is it?
` A. The '618 patent.
` Q. So, if you would, go to column 2,
`lines 34 to 36.
` A. Okay.
` Q. And it says, The present invention
`is based on the catalytic activity of a lipase
`enzyme to selectively degrade and volatilize
`components of fingerprints thus promoting
`active fingerprint removal.
` Do you see that?
` A. Yes.
` Q. What do you understand the meaning
`of active fingerprint removal to be?
` A. So, again, similar to what I said
`in my declaration, that the activity of the
`enzyme, which is a lipase, would catalyze the
`removal of visible fingerprint through the
`degradation and volatilization of the
`components of the fingerprint.
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` Q. Let me show you what's been marked
`as Exhibit 1012. Do you recognize that
`document?
` A. I think I looked at it. This --
`is this in the application of the patent
`itself? Looks like it.
` Q. Yes. So this was -- this was what
`I understand to be an office action or at least
`an amendment in response to a non-final office
`action that was -- that was served in the
`action to have this patent issued.
` A. Okay.
` Q. Have you read it before?
` A. I think I saw it before and I
`looked it over. I did not look at it recently.
` Q. Okay. If you would go to the
`bottom of page 11. So you see where -- I think
`it's the -- maybe the penultimate sentence:
`Thus, the need to facilitate removal of
`fingerprints.
` Do you see where I'm reading
`there?
` A. I do.
` Q. So it says, Thus, the need to
`facilitate removal of fingerprints from a
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`surface has been recognized, but that need has
`not been suitably satisfied prior to
`applicants' invention. And you understand
`they're talking about the invention that's
`announced in the '618 patent?
` A. Yeah.
` Q. As was made clear by the examples
`in -- presented in the current specification,
`applicants' lipase-associated coatings or
`substrates promote fingerprint removal by
`vaporization, for example, without the need for
`physical washing such as with water.
` Do you see where I read that?
` A. Yes.
` Q. Next sentence, The presently
`claimed invention provides for the first time a
`method of facilitating passive removal of
`fingerprints from a surface organic or
`inorganic addressing the long-felt need
`fingerprint removal without user input and
`compatible with many support materials.
` Do you see where I read all that?
` A. Yes.
` Q. Do you believe that the term
`passive removal at the top of page 12 is the
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`same as the same term you used earlier when I
`asked you about the definition of passive
`removal?
` MR. LUKEN: Objection.
` You can answer.
` A. There are really two different
`aspects of this passive. What I was mentioning
`earlier and what was in the '618 patent had to
`do with the activity of the enzyme. That's an
`active event, catalytically active.
` I think what they're meaning here,
`what I read this, is that the previous sentence
`indicates that the lipase will promote, you
`know, basically facilitate fingerprint removal
`by vaporization without the need for physical
`washing, such as with water.
` And I think what they're getting
`at here is without the need of physical washing
`with water. So that -- that's how I read the
`term passive in regards to what is said here,
`as opposed to the actual putting an enzyme or a
`protein in a material, putting aside the
`washing aspect of it.
`BY MR. FASSOLD:
` Q. Does the '618 patent facilitate
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`the passive removal of fingerprints from any
`surface?
` MR. LUKEN: Objection.
` A. Yeah, I think, again, I answered
`it from the standpoint and in our discussion of
`what a lipase would do. Since the discussion
`that we had was focused on the activity of a
`lipase, that's what I look at as an active
`fingerprint removal.
` From the standpoint of the rest of
`it, which is, okay, you don't have to then wash
`it, that's inherent in the activity of the
`enzyme because it leads to vaporization.
` The passive aspect of what we see
`here on this office action suggests that
`passive -- the term passive relates to the
`subsequent effect, which would be that you don't
`in this case need to wash the residual material.
`BY MR. FASSOLD:
` Q. Dr. Dordick, I think I asked you
`last time I took your deposition about the
`areas of your expertise. And do you recall
`what your answer was?
` A. Well, would be the same as what my
`expertise is today. So I have expertise in
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`biochemical engineering, biochemistry,
`chemistry, and material science.
` Q. Do you have expertise in any other
`fields?
` A. Well, I think they're going to be
`encompassed in one or more of those areas, so
`there are subfields. I can't remember exactly
`what I said at that time, so --
` Q. Have you ever held yourself out as
`a expert in fingerprints?
` A. No.
` Q. Are you a fingerprint expert?
` A. No, I'm not a forensics expert.
` Q. That's not my question. Are you a
`fingerprint expert?
` A. I think they're kind of related.
`So, no.
` Q. Okay. So fingerprint expertise
`and forensic expertise are related?
` A. Well, I think that given that the
`actual fingerprint, the methods of crime scene
`investigation related to that, that would all
`be related, obviously, through fingerprint and
`forensic investigation. So I would say that
`fingerprint -- aspects of the fingerprints that
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`are specific to investigations would fall under
`forensics.
` Aspects of what are the components
`of fingerprints is really more of an analytical
`chemistry type of question, which is
`essentially how Buchanan treated her work.
` Q. Do you have an expertise in the
`components of fingerprints?
` A. Well, I certainly have an
`expertise in the chemistry that's -- the
`chemistry of the molecules that are in
`fingerprints, the biochemistry of bodily fluids
`and how they're generated, and the analyses
`that are used such as GC mass spec.
` Q. Outside this matter, have you ever
`studied fingerprints?
` A. No. But I have studied many of
`the components that are in fingerprints.
` Q. You've studied proteins, and
`proteins might be in fingerprints, but --
` A. Well, but I've also studied many
`of the molecules. We've looked at cholesterol,
`cholesterol esters, we've looked at squalene
`and other isoprenoids. So many of those
`species that are present in fingerprints we've
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`worked with, we've synthesized, we've used
`enzymes to carry out modifications.
` Q. And as a result of not -- well,
`just to be sure, you have no expertise in
`forensics?
` A. No.
` Q. No, you don't, or, no, you
`disagree with my --
` A. No, no, I do not. I'm not a
`forensic scientist.
` Q. And as a result of not having any
`expertise in forensic science or fingerprints,
`you do not know the most abundant component of
`a fingerprint?
` MR. LUKEN: Objection.
` A. Well, I know what -- I know what
`some of the major components are such as
`squalene, in some cases cholesterol. So most
`of these components are quite hydrophobic and
`they would make sense from the secretions that
`occur in the human body. So from that
`perspective, I can say that I know enough about
`those components that would go into a
`fingerprint to be able to opine on it.
`BY MR. FASSOLD:
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` Q. Do you know, yes or no, the most
`abundant component in a fingerprint?
` A. I believe it's squalene. That
`would be the most abundant small molecule.
` Q. What's the most abundant large
`molecule?
` A. Well, most abundant small organic
`molecule. There will be salts. Water would
`probably be by far the most abundant. But in
`terms of other molecules, it would be protein,
`there would be, you know, other kinds of
`triglyceride base materials, large long chain
`fats, waxes, things like that.
` Q. Do you agree that latent
`fingerprints are always invisible?
` A. I think the term latent indicates
`that they are not visible. That's how I read
`latent to be.
` Q. I'm going to show you what's been
`marked as Exhibit 1011. Do you recognize that
`document?
` A. It looks like another office
`action. I think I looked at that when
`preparing my report, but, again, I haven't
`reviewed it lately.
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` Q. Tell you what, we're going to come
`back to that. If you go back to your
`declaration and look at paragraphs 34 and 35,
`is it your opinion that Buchanan is not
`analogous art to the '618 patent?
` A. That's correct. I do not believe
`it's analogous.
` Q. Do you believe that Buchanan is
`not reasonably pertinent to the particular
`problem faced by the inventors of the '618
`patent?
` A. I don't believe it is pertinent
`for a number of reasons.
` Q. Where is it disclosed in Buchanan
`that latent fingerprints in Buchanan were not
`visually apparent to the naked eye at the time
`they were made?
` MR. LUKEN: Objection. Can I have
`that read back?
` (The record was read.)
` MR. LUKEN: Okay. I'm going to
`object, but you can answer.
`BY MR. FASSOLD:
` Q. And here's Exhibit 1013. First of
`all, what is Exhibit 1013?
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` A. It's the Buchanan, et al. paper.
` Q. And just so that the record's
`clear, where is it disclosed in Buchanan that
`latent fingerprints in Buchanan were not
`visually apparent to the naked eye at the time
`they were made?
` A. Well, I think that Buchanan
`doesn't specifically state whether it's visual
`or not except that her methods specifically
`focus on things that would be latent, not
`patent, not visible -- not visible.
` So, for example, in the
`introduction in the second paragraph, they --
`Buchanan indicates that -- this is one, two --
`four lines from the bottom -- and I'll just
`read it. Samples were tested by conventional
`dusting over a several-day period.
` So conventional dusting indicates the
`need to enable a print to be detected, which would
`suggest to me that these prints were not visible.
` Q. Do you agree that touchscreen
`displays are an article of interest in the '618
`patent upon which fingerprints are formed?
` A. I don't know if they specifically
`state touchscreen. They may have.
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` Q. Go ahead and look at column 1,
`line 16 of the '618 patent.
` A. Column 1, what line?
` Q. Line 16.
` A. Yes, they're in there.
` Q. So you agree that touchscreen
`displays are an article of interest in the '618
`patent upon which fingerprints are formed?
` A. To the extent that that's one of
`the components indicated right off the bat by
`the inventors, I would expect that would be an
`article of interest.
` Q. Do you agree that glass surfaces
`are an article of interest in Buchanan upon
`which fingerprints are formed?
` A. Yes.
` Q. What factors result in a
`fingerprint made upon glass surfaces being not
`visually apparent to the naked eye and
`fingerprints made on touchscreens being
`visually apparent to the naked eye?
` MR. LUKEN: Objection. Compound.
` A. Well, I think that, you know,
`really one -- a visible fingerprint is
`something that clearly happens at an early
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`stage of the aging process. So a fingerprint
`that's left early on such as using a
`touchscreen where you want to use it quite a
`bit, you want to remove as much as you can that
`would be visible, which would interfere with
`the use of the touchscreen or at least visibly
`looking through the screen. And whereas the --
`as they age, as the fingerprints age, as
`evaporation occurs and so forth, you lose that
`visible fingerprint and, as a result, you go to
`what's called the latent print.
` So, really, it's a question of the
`aging, the nature of the print itself, of
`course, the various components that make up the
`deposit of the fingerprint.
`BY MR. FASSOLD:
` Q. So it's your opinion that
`vaporization causes a visual fingerprint to
`transform into a latent fingerprint?
` A. There are some events that occur
`that take a visible print and turn it into an
`invisible latent print. The exact process, the
`exact methods in doing so, I don't know.
`However, there are two different kinds.
` Not being a forensics expert, I
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`can certainly indicate that there are two types
`of fingerprints, one that you can see and one
`that you cannot. So they come -- obviously
`fingerprints come from a finger or other things
`that are visible, ultimately could become
`invisible. Visible means you have to have
`enough there to see it.
` Q. But in a prior answer you said
`that vaporization causes a visual fingerprint
`to transform into a latent fingerprint?
` A. Well, that would be the corollary
`to what I just said was, I don't know all the
`details behind that, but vaporization is
`something that could result in a loss of
`material that would be relevant in losing its
`visible appearance.
` Q. Dr. Buchanan, did you know any of
`the inventors of the -- excuse me.
`Dr. Dordick, did you know any of the inventors
`of the '618 patent?
` A. Yes, I do.
` Q. And who is that?
` A. Ping Wang.
` Q. And any other inventor?
` A. No, not that I know of.
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` Q. And what's the nature of your
`knowledge of Ping Wang?
` A. So Ping was a postdoc in my lab;
`followed his career obviously after he left my
`lab.
` Q. Did you ever correspond with him?
` A. Occasionally.
` Q. When was the last time you
`corresponded with him?
` A. I think it was at one of the
`meetings -- one of the American Institute of
`Chemical Engineers meeting in Minneapolis,
`which I think was two years or three years ago.
`I can't remember the exact time. Probably two
`years ago.
` Q. Have you ever had any discussions
`with Ping Wang about this proceeding?
` A. I have not.
` Q. Have you ever had -- have you ever
`been to Ping Wang's house or has he ever been
`to your house?
` A. I've never been to his house. He
`may have come to -- well, he certainly came to
`my house back in Iowa City because he was a
`postdoc when I was at the University of Iowa,
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`we would have lab meetings. Probably the last
`time he came to my house, so it would have been
`prior to 1998.
` Q. Do you consider him a friend?
` A. I consider him a colleague, not a
`friend; former postdoc and colleague.
` Q. Have you ever had any business
`dealings with him?
` A. No.
` Q. Did the applicants named in the
`'618 patent need to have an understanding of
`constituent chemical components of fingerprints
`to develop the disclosed coating?
` MR. LUKEN: Objection.
` A. I believe they would have to have
`enough of a knowledge to understand that a
`lipase would have the ability to catalyze
`ultimately fingerprint removal.
`BY MR. FASSOLD:
` Q. Okay. But would they need to have
`an understanding of constituent chemical
`components of fingerprints to develop the
`disclosed coating?
` MR. LUKEN: Asked and answered.
` A. Yeah, it was exactly what I said,
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`was that they would have to have a knowledge of
`the components such that they would know a
`lipase would have the ability to carry out the
`desired function.
`BY MR. FASSOLD:
` Q. Okay. So when you say components
`there, you're talking about the components of
`fingerprints?
` A. Right.
` Q. Okay. What methods did the
`applicants of the '618 patent use to determine
`constituent chemical components of
`fingerprints?
` A. I don't know if they actually put
`in here the actual components. They obviously
`had knowledge of -- and what is known in the
`art at the time, knowledge of
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