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`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC., ) IPR2017-00317
` ) Patent No. 8,989,830
` Petitioner, )
` )
` v. )
` )
` VALENCELL, INC., )
` )
` Patent Owner. )
` -------------------------)
`
` - - -
` WEDNESDAY, SEPTEMBER 13, 2017
` - - -
`
` Videotaped deposition of BRIAN W. ANTHONY, PH.D.,
` taken at the offices of Sterne Kessler Goldstein Fox
` 1100 New York Avenue, NW, Suite 600, Washington, D.C.,
` beginning at 9:02 a.m., before Nancy J. Martin, a
` Registered Merit Reporter, Certified Shorthand
` Reporter.
`
` Veritext Legal Solutions
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` 1250 Eye Street NW - Suite 350
` Washington, D.C. 20005
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`Veritext Legal Solutions
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`Page 1
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`VALENCELL EXHIBIT 2009
`IPR2017-00318
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC., ) IPR2017-00317
` ) Patent No. 8,989,830
` Petitioner, )
` )
` v. )
` )
` VALENCELL, INC., )
` )
` Patent Owner. )
` -------------------------)
`
` - - -
` WEDNESDAY, SEPTEMBER 13, 2017
` - - -
`
` Videotaped deposition of BRIAN W. ANTHONY, PH.D.,
` taken at the offices of Sterne Kessler Goldstein Fox
` 1100 New York Avenue, NW, Suite 600, Washington, D.C.,
` beginning at 9:02 a.m., before Nancy J. Martin, a
` Registered Merit Reporter, Certified Shorthand
` Reporter.
`
` Veritext Legal Solutions
` Mid-Atlantic Region
` 1250 Eye Street NW - Suite 350
` Washington, D.C. 20005
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Page 1
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`VALENCELL EXHIBIT 2009
`IPR2017-00318
`
`
`
`Page 2
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` A P P E A R A N C E S :
`
` B R A G A L O N E C O N R O Y P C
` B Y : T . W I L L I A M K E N N E D Y , E S Q .
` 2 2 0 0 R o s s A v e n u e
` S u i t e 4 5 0 0 W
` D a l l a s , T e x a s 7 5 2 0 1
` ( 2 1 4 ) 7 8 5 - 6 6 7 4
` b k e n n e d y @ b c p c - l a w . c o m
` R e p r e s e n t i n g P a t e n t O w n e r
`
` S T E R N E K E S S L E R G O L D S T E I N F O X
` B Y : M I C H A E L D . S P E C H T , E S Q .
` J A S O N A . F I T Z S I M M O N S , E S Q .
` 1 1 0 0 N e w Y o r k A v e n u e
` W a s h i n g t o n , D . C . 2 0 0 0 5
` ( 2 0 2 ) 3 7 1 - 2 6 0 0
` j f i t z s i m m o n s @ s k g f . c o m
` R e p r e s e n t i n g P e t i t i o n e r A p p l e , I n c .
`
` - a n d -
`
` S H O O K , H A R D Y & B A C O N L L P ( V I A T E L E C O N )
` B Y : R Y A N J . S C H L E T Z B A U M , E S Q .
` 2 5 5 5 G r a n d B o u l e v a r d
` K a n s a s C i t y , M i s s o u r i 6 4 1 0 8
` ( 8 1 6 ) 5 5 9 - 2 6 9 3
` r s c h l e t z b a u m @ s h b . c o m
`
` A L S O P R E S E N T :
` D A V I D C A M P B E L L , L E G A L V I D E O G R A P H E R
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` I N D E X
` PAGE
`
` TESTIMONY OF BRIAN W. ANTHONY, PH.D.
`
` BY MR. KENNEDY 5
`
` E X H I B I T S
` NUMBER DESCRIPTION MARKED
` Exhibit U.S. Patent 8,989,830 B2, 41 pages 80
` 1001
`
` Exhibit Prosecution History File 70
` 1002
` Exhibit Declaration of Brian W. 64
` 1003 Anthony, Ph.D., 82 pages
`
` Exhibit Academic C.V. of Dr. Brian W. 7
` 1004 Anthony, 20 pages
` Exhibit Mobile Monitoring with Wearable 59
` 1005 Photoplethysmographic Biosensors,
` 13 pages
` Exhibit U.S. Patent No. 4,830,014, 158
` 1007 11 pages
`
` Exhibit Decision Instituting Inter Parties 134
` Paper 7 Review, 27 pages
`
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` WASHINGTON, D.C., WEDNESDAY, SEPTEMBER 13, 2017;
`
` 9:01 A.M.
`
` - - -
`
` THE VIDEOGRAPHER: This is the start of media
`
` labeled No. 1 of the videotaped deposition of
`
` Dr. Brian W. Anthony in the matter of Apple, Inc. v.
`
` Valencell, Inc. This is in the United States Patent
`
` and Trademark Office before the Patent Trial and
`
` Appeal Board, No. IPR2017-00317.
`
` This deposition is being held at
`
` 1100 New York Avenue, Northwest, Suite 600,
`
` Washington, D.C., 20005 on September 13, 2017 at
`
` approximately 9:02 a.m.
`
` My name is David Campbell from TSG Reporting,
`
` Inc., and I'm the legal video specialist. The court
`
` reporter is Nancy Martin, in association with
`
` Veritext.
`
` Counsel, will you please identify yourselves
`
` for the record, and the witness will be sworn in and
`
` we can proceed.
`
` MR. KENNEDY: Bill Kennedy for patent owner,
`
` Valencell.
`
` MR. SPECHT: Michael Specht for petitioner,
`
` Apple, Inc. With me is Jason Fitzsimmons, also of
`
` Sterne Kessler Goldstein Fox on behalf of petitioner.
`
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`
`
` BRIAN W. ANTHONY,
`
` having been first duly sworn/affirmed,
`
` was examined and testified as follows:
`
`Page 5
`
` EXAMINATION
`
` BY MR. KENNEDY:
`
` Q. Good morning, Dr. Anthony. My name is Bill
`
` Kennedy, and I represent the patent owner in this
`
` matter, and I'll be asking you the questions today.
`
` I'd like you to start by introducing yourself for the
`
` record.
`
` A. My name is Brian W. Anthony.
`
` Q. And what's your understanding of why you're
`
` here?
`
` A. I agreed, as part of my deposition, to be
`
` cross-examined.
`
` Q. Have you ever been deposed before?
`
` A. Yes.
`
` Q. How many times?
`
` A. One other time.
`
` Q. Was that a patent matter?
`
` A. It was not.
`
` Q. What was that deposition relating to?
`
` A. It was for an antitrust case with the FTC.
`
` Q. Who were the parties in that antitrust case?
`
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` A. One of them was a company called Red Lake.
`
` Another was a company called -- I'm actually
`
` forgetting. It was 10 years ago.
`
` Q. So before we go into any further questions,
`
` I'd like to just go over some typical deposition
`
` ground rules and try to get you to agree to those.
`
` The first thing is I'd like you to let me
`
` finish asking my question before you answer. In
`
` exchange, I'll let you finish answering before I ask
`
` another question. Is that fair?
`
` A. Yes.
`
` Q. And then if you don't understand one of my
`
` questions, I'd like you to tell me so I can try to
`
` rephrase it. If you answer one of my questions
`
` without telling me you don't understand, I'll assume
`
` that you understood the question. Is that fair?
`
` A. Yes.
`
` Q. Okay. And then for answers, I'd ask that you
`
` give a verbal answer instead of a nod of the head or
`
` something like that so that the court reporter can
`
` transcribe your answers. Is that fair?
`
` A. Yes.
`
` Q. Is there any reason why you can't testify
`
` truthfully here today?
`
` A. No.
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` Q. Is there any reason why your testimony here
`
`Page 7
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` might be unreliable?
`
` A. No.
`
` Q. You understand that you're under oath today?
`
` A. Yes.
`
` Q. And do you understand that half truths are
`
` unacceptable answers?
`
` A. Yes.
`
` MR. KENNEDY: I'd like to start first with
`
` your background. I'm going to hand you what's been
`
` marked in the IPR as Apple -- sorry. Exhibit 1004.
`
` REPORTER MARTIN: You said it was previously
`
` marked?
`
` MR. KENNEDY: Yeah.
`
` (Deposition Exhibit 1004 was marked for
`
` identification.)
`
` BY MR. KENNEDY:
`
` Q. Do you recognize Exhibit 1004?
`
` (The witness reviewed Exhibit 1004.)
`
` THE WITNESS: Yes.
`
` BY MR. KENNEDY:
`
` Q. What is Exhibit 1004?
`
` A. It appears to be my academic CV.
`
` Q. Is this different than any other kind of CV
`
` that you have? You said, "academic CV."
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` A. I use the moniker "academic CVs." They tend
`
` to be 20-page documents that explain all papers, past
`
` work. So it's not an abbreviated version.
`
` Q. Do you see Section 3 in Exhibit 1004 labeled
`
` "Education"?
`
` A. Yes.
`
` Q. And then there's a column that says,
`
` "Degree." Do you see that?
`
` A. Yes.
`
` Q. And then for your B.S. degree you went to
`
` Carnegie Mellon University; correct?
`
` A. Yes.
`
` Q. And what degree did you receive?
`
` A. Mechanical engineering, bachelor of science
`
` in mechanical engineering with a minor in European
`
` studies.
`
` Q. So you didn't receive a degree in electrical
`
` engineering; is that correct?
`
` A. That is correct.
`
` Q. Do you see the row below that, "School, "MIT,
`
` Degree, SM"?
`
` A. Yes.
`
` Q. What specific degree was the SM degree?
`
` A. That was in mechanical engineering.
`
` Q. So for your master's, again, you did not
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` study electrical engineering?
`
` A. My degree was in mechanical engineering. I
`
` studied electrical engineering, mechanical
`
` engineering, computer science.
`
` Q. And in what capacity did you study electrical
`
` engineering?
`
` A. In my thesis I developed a technique to
`
` measure the temperature of silicon wafers undergoing
`
` rapid thermal processing and developed the mechanics,
`
` the optics, and the electronics to measure those
`
` characteristics. So both in my research and then the
`
` courses that I took.
`
` Q. So what specific thing did you do to develop
`
` the optics in that project?
`
` A. I developed the optics to do the beam forming
`
` that would take a pulsed laser and pass it through a
`
` conical winds to turn it into a ring, and then the
`
` interferometric objects to take a continuous wave
`
` laser and point it at the center of a ring, impinging
`
` on a silicon surface to detect converging thermal
`
` elastic waves, which captured the elastic properties
`
` of the silicon as the wave was propagating to it.
`
` Q. What do you mean you developed the optics to
`
` do the beam forming? Did you buy components? Did you
`
` design components and make them?
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` MR. SPECHT: Objection. Form. Sorry. I
`
` thought you were done.
`
` THE WITNESS: I'm sorry. Can you please
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`Page 10
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` repeat the question.
`
` BY MR. KENNEDY:
`
` Q. Sure. What did you mean by you developed the
`
` optics to do the beam forming? Did you design
`
` components or make them, or did you buy them off the
`
` shelf?
`
` MR. SPECHT: Objection. Form.
`
` THE WITNESS: So I assembled the optical
`
` system with commercially available optical components.
`
` BY MR. KENNEDY:
`
` Q. So you didn't design any optical components;
`
` is that correct?
`
` A. I guess it would depend on how you just
`
` define "design." I did not design a new lens to do
`
` this, but I did design the optical system to perform
`
` the measurements, yes.
`
` Q. What's the difference between those two
`
` things?
`
` A. An optical component would be something like
`
` an individual lens. An optical system would be a
`
` combination of lenses, lights, windows, transmissive
`
` material, cladding, for example.
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` Q. So I understand my question wasn't entirely
`
` clear to you. I meant what's the difference between
`
` designing a new lens versus designing a new optical
`
` system?
`
` A. So if I understand the question correctly --
`
` Q. I'll interrupt you so I can try to make it
`
` clearer.
`
` So you said, "I guess it would depend on how
`
` you just define 'design.' I did not design a new lens
`
` to do this, but I did design the optical system to
`
` perform the measurements, yes." So I'm trying to
`
` understand the distinction you're making there.
`
` What's the difference of designing a new lens versus
`
` designing an optical system?
`
` A. So I think as I said, an optical component, a
`
` single optical element like a lens is not something
`
` that I designed. I would -- I purchased lenses for --
`
` that had the correct shape. So I specified what
`
` lenses needed to be used and then bought the
`
` appropriate lenses.
`
` The design of the optical -- of an optical
`
` system is a unique arrangement of optical components.
`
` Several lenses, several light sources, several
`
` protectors.
`
` Q. So the fact that you bought a lens off the
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` shelf for the optical system doesn't take away from
`
` the fact that you put in some kind of design effort to
`
` make a unique arrangement of optical components; is
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`Page 12
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` that correct?
`
` A. Correct.
`
` Q. I'd like to go back to Exhibit 1004 and look
`
` at, again, Section 3, and moving down to your Ph.D.
`
` from MIT. Can you tell me what specific focus your
`
` Ph.D. was on?
`
` A. My specific focus of the doctoral thesis was
`
` in the video-based system monitoring. My minor of
`
` study was in electromechanical system design.
`
` Q. And what is "electromechanical system
`
` design"?
`
` A. That is the integration of electronics,
`
` mechanical components, software, and computation.
`
` Some would call it "mechatronics." Some would call it
`
` "robotics."
`
` Q. I'm sorry. Did you say electromechanics or
`
` electrical mechanical?
`
` A. Electromechanical.
`
` Q. And what specific work with optics did you do
`
` in your Ph.D. studies?
`
` A. In my Ph.D. studies, as I said, the thesis
`
` topic was a video-based system monitoring, principally
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` directed towards monitoring of manufacturing lines,
`
` the assembly of product happening at high speed or the
`
` movement of devices happening at high speed. In such
`
` systems the optical components include the lighting
`
` that's necessary to appropriately illuminate, the
`
` selection of lenses and cameras to appropriately frame
`
` and aim and acquire, the inclusion of -- to create
`
` some shadows in the control of lighting to make sure
`
` that the part or system under interrogation is being
`
` appropriately illuminated, for example.
`
` I would add to that, actually. Often, in
`
` looking at a particular scenario -- and I think one
`
` example that was in my thesis was examining a heart
`
` valve, a synthetic heart valve, undergoing lifetime
`
` testing, and in that system a synthetic heart valve,
`
` which was constructed with a polymer ring and real pig
`
` tissue as the potential surrogate was being explored
`
` as a potential candidate for valve replacement. That
`
` system, for example, would be tested in a novel
`
` constructive device that would allow fluid to be
`
` pumped through it to simulate the beating heart.
`
` In such a scenario you need to generally be
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` very creative in figuring out how you create the light
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` path to allow the camera to image the device, how you
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` get light into it.
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` So more often than not, when you're looking
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` at a need for video interrogation in a system that's
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` not plain and open to the visible environment, you
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` need to figure out how to get light into the system,
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` get light out of the system, and have the optical path
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` so that they can be videoed in this case.
`
` Q. In your answer just a moment ago you said you
`
` made a novel constructive device that would allow
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` fluid to be pumped through it to simulate the beating
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` heart. What was novel about it?
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` A. Many aspects of the device. The novelty in
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` terms of the construction of how to put the heart
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` valve in a fluid path and optical -- in a fluid path
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` and temperature path that would be mimicking the human
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` body. Additionally, the novelty that was added to it
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` was the techniques to get the correct illumination
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` along the pipe where the heart valve was located, and
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` then the baffling and camera framing, mirrors and
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` lenses, to get the image -- video imagery of the heart
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` valve.
`
` Q. You said, "Additionally, the novelty that was
`
` added to it was the techniques to get the correct
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` illumination along the pipe where the heart valve was
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` located." What do you mean by "the techniques to get
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` the correct illumination along the pipe"?
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` A. Well, for example, so we have a pipe. We
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` have a heart valve in the center of the pipe, and
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` we're looking down the pipe. And so you can't shine
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` light from the outside. You don't want to create
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` adverse shadowing. So you need to consider getting
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` light either from the bottom or from the top. And
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` different aspects of the dynamics you may want to
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` observe would be appropriately illuminated from either
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` direction. So to have the flexibility to illuminate
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` the heart valve to capture the dynamics of the valve
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` itself.
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` Q. The light pipes were known before this system
`
` was developed; correct?
`
` A. Correct.
`
` Q. So what specifically about using these light
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` pipes made this system novel?
`
` MR. SPECHT: Objection. Asked and answered.
`
` THE WITNESS: I would say I have described
`
` what it was, but I think it's the complete system
`
` integration to capture the appropriate -- to capture
`
` the data.
`
` BY MR. KENNEDY:
`
` Q. A while back you said, "So more often than
`
` not when you're looking at a need for video
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` interrogation in a system that's not plain and open to
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` the visible environment, you need to figure out how to
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` get light into the system, get light out of the
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` system, and have the optical path so they can be
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` videoed in this case." What did you mean by "you need
`
` to figure out how to get light into the system"?
`
` A. We need to figure out how to illuminate the
`
` device. So putting windows in appropriate places,
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` putting mirrors in appropriate places so that you have
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` photons bouncing onto the surface, photons bouncing
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` off the surface.
`
` Q. And your system putting windows in the
`
` appropriate place is part of the novelty of that
`
` system?
`
` A. Yes. I think it's for me, reflecting upon
`
` it, hard to say what -- the complete system was novel.
`
` So it was an individual component known, yes. Did I
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` assemble things that were known and purchasable, yes.
`
` So it was really creating the -- using the cameras and
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` lights in their -- sort of their standard way that you
`
` would know how to assemble, to create, to capture the
`
` motion of this heart valve.
`
` So the system itself to capture the heart
`
` valve was really -- the motion of the heart valve was
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` the novelty.
`
` Q. Sorry. That last sentence you said, "So the
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` system itself to capture the heart valve was really
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` the motion of -- the heart valve was the novelty,"
`
` what did you mean by that?
`
` A. I believe up until that point nobody had been
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` successfully able to capture the ex vivo but simulated
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` physiological conditions of a heart valve undergoing
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` rapid lifetime testing.
`
` Q. And what about your system allowed this to be
`
` achieved?
`
` MR. SPECHT: Objection. Asked and answered.
`
` THE WITNESS: I'm confused as to how to
`
` explain it in a different way but...
`
` BY MR. KENNEDY:
`
` Q. I'm not asking -- if it's the same answer --
`
` I just didn't know if it applied in the same way. So
`
` I'd ask the same question again, but it's okay if you
`
` say the same -- if your answer is still the same.
`
` That's fine.
`
` A. The answer is still the same.
`
` Q. And what's that same answer?
`
` A. I can -- I gave a very long answer. I'm
`
` sorry. Please repeat the question, and I'll try to
`
` paraphrase what my previous answer was.
`
` Q. That's fine. Please. Thank you. I
`
` appreciate it.
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` A. Can you please repeat the question.
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` Q. You said, "I believe up until that point
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` nobody had been" able to -- "been successfully able to
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` capture the ex vivo but simulated physiological
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` conditions of a heart valve undergoing rapid lifetime
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` testing." I wanted to know what about your system
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` allowed this to be achieved?
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` MR. SPECHT: Same objection.
`
` THE WITNESS: And I'll try to paraphrase.
`
` Again, it's the mechanical construct of the whole
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` heart valve, the fluid system to move the valve, the
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` optical system to illuminate, the optical system to
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` video. So everything assembled to record the heart
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` valve.
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` BY MR. KENNEDY:
`
` Q. And all the components in that system are
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` previously known; correct?
`
` A. Correct.
`
` Q. So it's just the arrangement of those
`
` components that was novel?
`
` A. I'd have to think further back and see -- to
`
` recall whether there were any particular components
`
` that I described from scratch. I'd say predominantly,
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` though, it was known components.
`
` Q. You can't -- sitting here today, you can't
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` think of any components that were new in that device;
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` correct?
`
` A. The piping system. There was no piping
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` system that you would buy into which you would place a
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` heart valve. You can't go to Granger and order heart
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` valve piping.
`
` Q. But light pipes were known then; correct?
`
` A. Correct.
`
` Q. So part of the novelty of the invention was
`
` using a known light pipe in a new way?
`
` A. I think I want to be careful with the term
`
` "light pipe." The pipe wasn't what an expert would
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` typically think of as a light pipe. It was a pipe
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` into which the heart valve was placed. Light would
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` also go up and down the pipe. So in that sense the
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` light was transmitting pipe -- or the pipe was
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` transmitting light, allowing it to propagate.
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` And in a general sense, did the pipe have the
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` effect of allowing light to go in and out, yes. Was
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` it a light pipe as, say, you find in different
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` lighting systems, for example, flatbed scanners, no.
`
` Q. But the purpose of those components was to
`
` illuminate the heart valve with light; correct?
`
` A. Well, the intent of an optical system in
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` general is to provide lighting, windows, material that
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` light can propagate through, air, plastic, glass. So
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` it's -- in the majority of optical systems, those are
`
` the standard optical components. Lenses, lights,
`
` windows, baffling, shading in a medium through which
`
` the light is passing.
`
` Q. But an inventor can take those standard
`
` optical components and arrange them in a way that's
`
` novel; correct?
`
` A. In this case I was solving a novel
`
` application.
`
` Q. So I don't think you answered my question.
`
` My question was you listed off a bunch of optical
`
` elements, lightings, windows, material, that light can
`
` propagate through, air, plastic, and glass. You said
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` those were standard optical components; correct?
`
` A. Correct.
`
` Q. What I asked was an inventor can use those
`
` known components to come up with a novel thing;
`
` correct?
`
` A. Correct.
`
` Q. So we've been talking about in the heart
`
` valve system for a while. Is there anything else that
`
` you did in your Ph.D. that involved optics?
`
` A. The entire thesis was in some way involved
`
` with optics and its video. You can't do video without
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` optical systems. So I used the heart valve as one
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` example of a system that was interrogated.
`
` Q. Are there any other things that you worked on
`
` at your Ph.D. that involved guiding light?
`
` A. As part of my thesis or as part of my
`
` graduate research? I also was involved in using
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` borescopes to interrogate engine parts. I was
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` involved with courses that I either TA'ed or took that
`
` would design optical components. I was a TA for an
`
` optical engineering class, and certainly, optical
`
` components. Windows, lights were all part of that
`
` class that I took. So that's all part and parcel of
`
` what my doctoral studies included.
`
` Q. During your doctoral studies, did you come up
`
` with any optical elements that you considered novel?
`
` A. Please, can you ask the question again.
`
` Q. During your doctoral studies, did you come up
`
` with any optical elements that you considered novel?
`
` A. And by "element," if I can ask for
`
` clarification, you mean a single optical component?
`
` Q. Sure.
`
` A. I guess it depends on how broadly you want to
`
` define "novel." So do they design novel windows, yes.
`
` Do they sort of arrange optical transmissive material
`
` in novel ways, yes. Did I design any new lenses, no.
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` I would also add that my -- during my doctoral studies
`
` I was also running and starting my company, and there
`
` were optical devices and techniques that -- I was
`
` doing that.
`
` Q. When you said, "Did I design novel windows,
`
` yes," what specific novel windows did you design?
`
` A. I'll continue to use the heart valve.
`
` Q. So I'm not just asking you about the heart
`
` valve. I'm asking about which novel windows did you
`
` design?
`
` MR. SPECHT: Counsel, please let the expert
`
` finish his answer.
`
` MR. KENNEDY: I thought it would just be
`
` easier if I cut him off there so that I could explain
`
` since I saw where his answer was going.
`
` THE WITNESS: So a novel -- in this sense, a
`
` novel window is generally not designed in isolation.
`
` A novel window is generally designed with a system in
`
` mind. It's more common to find individual -- so you
`
` don't generally find them by windows. You buy lenses.
`
` And so it's hard to say that I've designed a window
`
` that could have been released for commercial product
`
` and reused in many different ways. It's always in the
`
` context of getting light into a particular area that
`
` needs to be illuminated.
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` BY MR. KENNEDY:
`
` Q. So the novelty in the windows that you
`
` designed was in the context of getting light into a
`
` particular area that needs to be illuminated?
`
` A. Correct.
`
` Q. We've already heard about the heart valve
`
` example. Is that an example of one of those windows?
`
` A. There were certainly windows in that system.
`
` Q. And did you -- were you involved in any other
`
` systems in which you found that the novelty in the
`
` windows was designed in the context of getting the
`
` light into a particular area that needs to be
`
` illuminated?
`
` A. Most optical systems, when you're trying to
`
` direct and guide light to a particular location, are
`
` going to involve windows. So I'd say the majority of
`
` the systems that I would video, or if they were in
`
` enclosed spaces, would in some way have, as a
`
` component, a technique or a window, an opening through
`
` which to get light.
`
` Q. I'd like to go back to your original answer.
`
` You said, "So did I design novel windows, yes." And I
`
` asked you what specific novel windows that you
`
` designed. I believe that the ultimate answer that
`
` came down to was "the novelty in the windows designed
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` was in the context of getting light into the
`
` particular area that needs to be illuminated"; is that
`
` correct?
`
` A. Correct. That sounds like what I said.
`
` Q. And then the example you provided, that was
`
` your pig heart valve example; is that correct?
`
` A. Correct. That is one example, yeah.
`
` Q. Are there any other examples of that?
`
` A. As I think I also mentioned, involved in
`
` using borescopes to examine the insides of engines, of
`
` turbines. What are some other examples? In the
`
` context of our -- for -- are you asking just in the
`
` context of the things that I did at MIT as part of my
`
` doctoral work?
`
` Q. For now, yes.
`
` A. Okay. I was also involved with systems to do
`
` robotic tele-operation using cameras to observe motion
`
` in the environment. So those camera systems would be
`
` behind walls or on gimbals. And, again, those are
`
` windows in those systems. Those are some examples.
`
` I'm sure there are others, but, now, going back to my
`
` doctoral thesis is --
`
` Q. Can you think of any other examples?
`
` A. I think one of the other examples that
`
` probably made it into my thesis was the diaper
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` packaging line where we had to monitor the flow of
`
` diapers being packaged. Glue was being applied to the
`
` diaper as part of a machine, and it passed through a
`
` machine that would put paper on top of it and passed
`
` into an additional machine to package it. We needed
`
` to get a view inside of one of the pieces of
`
` equipment. So we had to redesign the equipment to
`
` have a window into the equipment to get a view of the
`
` gluing and attaching of paper to the glue as another
`
` example. I'm certain there are others.
`
` Q. What are the others?
`
` A. I did already highlight my master's work,
`
` which was -- the term included windows in both the use
`
` of the pulsed laser for generating thermal elastic
`
` wave and the detection of the infometric laser to do
`
` detection of service motion.
`
` Also, as part of the consulting that I was
`
` doing during my studies, I worked for a consulting
`
` company called Opticus where I designed optical
`
` height-of-fill systems for monitoring f
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