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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ---:---
`
`FLIR SYSTEMS, INC. and
`FLIR MARITIME US, INC.
`(f/k/a RAYMARINE, INC.),
`
` ) Case No.
` ) IPR2017-00946
` )
` ) Patent 7,268,703 B1
` )
` )
` )
` )
` )
` )
` )
` Patent Owner.
`____________________________ )
`
` Petitioner,
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` vs.
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`GARMIN SWITZERLAND GmbH,
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` VIDEO CONFERENCE DEPOSITION OF
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` MICHAEL S. BRAASCH, PhD
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`Taken on behalf of Patent Owner Garmin Switzerland
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`GmbH at Certified Legal Video Services, 1111 Bishop
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`Street, Suite 500, Honolulu, Hawaii 96813, commencing
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`at 9:35 a.m. on October 16, 2017 pursuant to Notice.
`
`Before: WILLIAM T. BARTON, RPR, CSR NO. 391
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`MIDWEST LITIGATION SERVICES
`www.midwestlitigation.com
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2017-00946
`Garmin EX2004 Page 1
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`
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 2
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`APPEARANCES:
`
` For Petitioner
` FLIR Systems, Inc. and FLIR Maritime US, Inc.
` (f/k/a Raymarine, Inc.)
` BRIAN FERGUSON, ESQ.
` Weil Gotshal & Manges LLP
` 1300 Eye Street NW, Suite 900
` Washington, DC 20005
` (202) 682-8000
` brian.ferguson@weil.com
`
` For Patent Owner
` Garmin Switzerland GmbH
` JENNIFER C. BAILEY, ESQ.
` ADAM SEITZ, ESQ.
` (present by video conference)
` ERISE IP, P.A.
` 6201 College Boulevard, Suite 300
` Overland Park, Kansas 66211
` (913) 777-5600
` Jennifer.Bailey@EriseIP.com
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`MIDWEST LITIGATION SERVICES
`www.midwestlitigation.com
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2017-00946
`Garmin EX2004 Page 2
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`
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 3
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` INDEX
`
` EXAMINATION
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`Witness Name Page
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`MICHAEL S. BRAASCH, PhD
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` CROSS BY MS. BAILEY ....................... 4
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` REDIRECT BY MR. FERGUSON .................. 84
`
` EXHIBITS
`
`Exhibit Description Page
`
`1000 Petition for Inter Partes Review of 4
` U.S. Patent 7,268,703, pages 1
` through 77
`
`1001 U.S. Patent 7,268,703 B1, 4
` FLIR-1001.001 through FLIR-1001.020
`
`1003 Declaration of Michael S. Braasch 4
`
`1005 Automated Route Planning, 4
` FLIR-1005.001 through FLIR-1005.132
`
`1006 Electronic Navigation Systems, 4
` FLIR-1006.001 through FLIR-1006.168
`
`1017 Voyage Planning in ECDIS, 4
` FLIR-1017.001 through FLIR-1017.008
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`MIDWEST LITIGATION SERVICES
`www.midwestlitigation.com
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2017-00946
`Garmin EX2004 Page 3
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`
`
`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 4
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` (Whereupon, Petition for Inter Partes Review of
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`U.S. Patent 7,268,703, pages 1 through 77 was
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`pre-marked as Exhibit 1000 for Identification.)
`
` (Whereupon, U.S. Patent 7,268,703 B1,
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`FLIR-1001.001 through FLIR-1001.020 was pre-marked as
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`Exhibit 1001 for Identification.)
`
` (Whereupon, a Declaration of Michael S. Braasch
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`was pre-marked as Exhibit 1003 for Identification.)
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` (Whereupon, Automated Route Planning,
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`FLIR-1005.001 through FLIR-1005.132 was pre-marked as
`
`Exhibit 1005 for Identification.)
`
` (Whereupon, Electronic Navigation Systems,
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`FLIR-1006.001 through FLIR-1006.168 was pre-marked as
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`Exhibit 1006 for Identification.)
`
` (Whereupon, Voyage Planning in ECDIS,
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`FLIR-1017.001 through FLIR-1017.008 was pre-marked as
`
`Exhibit 1017 for Identification.)
`
` MICHAEL S. BRAASCH, PhD,
`
`Called as a witness by Patent Owner, having been
`
`first duly sworn, was examined and testified as
`
`follows:
`
` CROSS-EXAMINATION
`
`BY MS. BAILEY:
`
` Q. Good morning, Dr. Braasch. Thank you for
`
`being here.
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`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2017-00946
`Garmin EX2004 Page 4
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 5
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` A. Good morning.
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` Q. My name is Jennifer Bailey. I have here
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`with me my partner Adam Seitz. We are with the law
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`firm IRISE IP in the Kansas City, Missouri area.
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` I know you traveled a long way for your
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`deposition today, and we appreciate it.
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` You're about five hours behind us; is that
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`correct?
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` A. I think that's about right, yes.
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` Q. I mention that because it might make some
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`of our deposition today a little bit odd or awkward
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`with respect to timing. I want to make clear that if
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`at any time you need a break, please let know,
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`whether it's a restroom break or lunch or dinner
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`break especially since our timing is kind of off
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`today.
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` A. I will do that.
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` Q. Great. Could you please state your full
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`name and spell it and the address?
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` A. It's Michael Scott Braasch, M-I-C-H-A-E-L,
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`S-C-O-T-T, B-R-A-A-S-C-H.
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` And with regard to your question about my
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`address are you asking for my current address,
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`permanent address or both?
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` Q. How about your permanent address in the
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`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2017-00946
`Garmin EX2004 Page 5
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`
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 6
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`U.S.
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` A. My permanent address is 19134 South Canaan,
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`C-A-N-A-A-N, Road. The City is Guysville spelled
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`G-U-Y-S-V-I-L-L-E. The State is Ohio. And the zip
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`is 45735.
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` Q. Great. Thank you. So, I'm going to ask a
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`series of questions today. If you don't understand
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`one of my questions, please, do let me know and I'll
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`be glad to repeat it or rephrase is.
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` If you need a question repeated, please go
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`ahead and ask. Is that okay with you?
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` A. That will be fine.
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` Q. Okay. So I'm going to assume that if you
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`answer my question that you understand my question.
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` Is that agreeable to you?
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` A. Yes, it is.
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` Q. Great. And I also already mentioned that
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`if you do need to take a break just let me know. So
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`in preparing for your deposition today could you walk
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`me through what you did to prepare?
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` A. Yes. I reviewed my declaration. I
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`reviewed the patent and the challenged claims. I
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`reviewed the art that I analyzed in preparing my
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`declaration.
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` I also reviewed the petition. And I
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`IPR2017-00946
`Garmin EX2004 Page 6
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 7
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`reviewed the board's institution decision. I also
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`met with counsel.
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` Q. Did you review Garmin's preliminary
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`response filed in the proceeding?
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` A. I believe I did briefly.
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` Q. What counsel did you meet with?
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` A. I met with Mr. Ferguson from Weil.
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` Q. Only Mr. Ferguson?
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` A. That's correct.
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` Q. Was anyone else on the phone perhaps from
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`FLIR?
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` A. No, they were not.
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` Q. Okay. How long did you meet with Mr.
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`Ferguson?
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` A. Approximately six hours.
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` Q. Did you meet with him yesterday?
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` A. Yes.
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` Q. Have you ever served as an expert witness
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`in a patent matter before?
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` A. Yes, I have.
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` Q. What matter was that?
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` A. I've been doing this for ten years and
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`probably a couple dozen cases. I'm not sure where I
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`would start.
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` Q. So you've been a patent expert in a couple
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`Fax: 314.644.1334
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`IPR2017-00946
`Garmin EX2004 Page 7
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 8
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`of dozen cases?
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` A. Approximately.
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` Q. Have you ever worked with FLIR before?
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` A. No, I have not.
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` Q. What navigation companies have you worked
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`with before?
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` MR. FERGUSON: Object to the form.
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` A. Could you rephrase the question.
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` Q. Sure. You said you've been a patent expert
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`in a couple of dozen cases. Have you ever worked
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`with a navigation company or been an expert for the
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`navigation company?
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` A. Yes. In the sense of companies that have
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`provided products that work in the area of
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`navigation. So, for example, in the previous case I
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`worked for Garmin. And I have worked for -- I worked
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`for phone, mobile phone manufacturers and wireless
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`communications companies that have provided products
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`to their customers that were used for the purposes of
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`providing directions, for example.
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` Q. Thank you. Your declaration that you
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`prepared for this proceeding that you said that you
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`reviewed, how did you prepare that declaration?
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` A. I started by reviewing the patent and the
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`challenge claims. I reviewed art that counsel
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`IPR2017-00946
`Garmin EX2004 Page 8
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 9
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`provided to me. As I formulated my opinions I also
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`collaborated with counsel in the preparation of the
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`declaration.
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` Q. Did counsel prepare the first draft of the
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`declaration?
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` A. Off the top of my head my recollection is
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`that counsel prepared an initial shell or outline
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`that I populated with various parts. Counsel in
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`collaboration with me as forming my opinions provided
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`some input into the shell as well. So it was a
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`collaborative process as the first draft was built.
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` Q. Thank you. So I want to put that to
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`another topic today. This matter uses a lot of terms
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`and jargon that I want to try to kind of get down for
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`reference purposes. I want to start out with the
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`concept of electronic charts. First, could you
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`describe to me what a hydrographic feature is?
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` A. Well, I don't recall relying on
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`specifically a definition of hydrographic features
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`for my declaration. Did I use that in my
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`declaration? I may have and I just can't remember
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`off the top of my head.
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` Q. One of the references that you cite to
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`relies on, uses the term "hydrographic feature". My
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`question is -- let me rephrase my question.
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`Fax: 314.644.1334
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`IPR2017-00946
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 10
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` Do you know what a hydrographic feature is?
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` A. My general understanding is it can
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`reference various features of a waterway, could be
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`water depths or things that are in the water that
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`could potentially form an obstruction to a vessel.
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` Q. So the hydrographic feature is a feature
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`that could potentially form an obstruction to a
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`vessel?
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` A. That's one example.
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` Q. Any other examples?
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` A. Not that are coming to mind immediately.
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` Q. Okay. What is a cartographic feature?
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` A. I'm going to take a look at some of the
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`references I have.
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` Q. Sure. Could you let me know what reference
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`you're looking at when you pull it out?
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` A. Yes, I will do that.
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` (Pause.)
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` A. I'm not finding the particular item that I
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`thought I was recalling from the references. But in
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`answer to your question, a cartographic feature in
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`the context of the prior art and electronic
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`navigation charts would be some element of a, element
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`of a chart or a map.
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` Q. So a cartographic feature is an element of
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`IPR2017-00946
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 11
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`a chart or a map?
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` A. I think that would be one example, yes.
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` Q. Any other examples?
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` A. Not that are coming to mind immediately.
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` Q. Are there any differences between a
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`hydrographic feature and a cartographic feature?
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` A. To the extent that a hydrographic feature
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`isn't represented on a chart, then it would still
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`exist but wouldn't be a feature on a particular
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`chart.
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` Q. Could you give me a general description of
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`how electronic charts are used in marine navigation?
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` A. Well, one example would be within the ECDIS
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`system, that's E-C-D-I-S, that is in the art that I
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`have opined on in my declaration.
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` Q. So one example of an electronic chart is
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`the ECDIS that you opined on; is that correct?
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` A. No. The electronic charts are used in
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`ECDIS among other things that ECDIS is used for.
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` Q. How are the electronic charts used in
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`ECDIS?
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` A. Well, they are used in a variety of ways.
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`One is to display the chart to or display a given
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`chart to the person on the boat or ship that is
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`involved with the ship's navigation. The position
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 12
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`and course of the boat can be depicted on the charts
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`on ECDIS. There are other things that ECDIS does as
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`well that I've talked about in my declaration that
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`are discussed in the prior art.
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` Q. I want to come back to the features of
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`ECDIS in a couple of minutes. Are there different
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`types of electronic charts that are used for marine
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`navigation?
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` A. I believe there are. But I can't quote
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`examples right off the top of my head.
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` Q. Are you familiar with Raster charts,
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`R-A-S-T-E-R?
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` A. Yes, I am.
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` Q. Could you explain to me what a Raster chart
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`is, please?
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` A. Basically, a Raster chart is a scanned
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`image of a chart. So it's kind of like taking a
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`photocopy, only the copy is showing up in the
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`computer rather than on paper.
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` Q. In addition to Raster charts what other
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`electronic charts are there for marine navigation?
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` A. Well, another example would be a vector
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`based chart.
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` Q. Could you explain to me what a vector based
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`chart is?
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`Fax: 314.644.1334
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`IPR2017-00946
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 13
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` A. In a vector image then the various elements
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`within the chart are represented in such a way that
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`they can be grouped, they can be scaled. And in
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`general the vector approach provides more
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`flexibility, typically provides better resolution for
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`the user.
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` Q. What do you mean by the various elements
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`can be "grouped" or "scaled"?
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` A. Well, for example, if in a Raster chart
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`then the various elements of the chart that's been
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`scanned are just treated. Each pixel is just, a
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`black and white image, for example, the individual
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`pixel would be black or white. That's it. That's
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`all that's known in the Raster image.
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` Whereas in a vector approach a line, for
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`example, is represented in a different way. And what
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`it allows the computer to do is to recognize the, for
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`example, the location and length and orientation of a
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`line.
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` And when that overall chart is zoomed in or
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`out then the computer is able to, is able to redraw
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`that, in this example, a line on the chart, is able
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`to redraw that at the scale of whatever is being
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`zoomed to.
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` Whereas in a Raster image the computer is
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 14
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`unaware that these various pixels are actually
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`connected. That's where resolution can get lost in a
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`Raster image.
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` Q. So what type of charts does ECDIS use?
`
` A. My recollection is that in the history of
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`the development of ECDIS since the mid nineties, I
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`believe both kinds of charts have been utilized in
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`various products. I believe the Tetley reference
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`goes into that in some detail. I don't remember the
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`details off the top of my head.
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` Q. Is there a difference between an electric
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`chart and an electronic navigational chart?
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` (Pause.)
`
` A. The term "electronic navigation chart" or
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`ENC is a term of art within marine navigation.
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`However, the Tetley reference, for example, has,
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`Chapter 7 is titled Electronic Charts as a generic
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`term.
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` Certainly an electronic navigation chart is
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`a chart used specifically in the navigation context.
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`But I think the Tetley reference would indicate that
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`the term "electronic charts" may also be utilized in
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`marine navigation as well. But electronic navigation
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`chart is a particular term of art within the marine
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`navigation community.
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` Q. Explain to me why it is a term of art.
`
` (Pause.)
`
` (Off the record discussion.)
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` A. I'm looking at the Tetley reference on the
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`Bates page 102 which is page 230 of Tetley. And this
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`section 7.2.3 is titled, Electronic Navigational
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`Charts ENC.
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` As Tetley states here these, referring to
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`electronic navigation charts, are the designated
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`charts for the ECDIS system. So that's why
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`electronic navigation charts is a term of art.
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` Q. Thank you. For the record Tetley is
`
`entered as Exhibit 1003.
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` MR. FERGUSON: 1006.
`
` Q. I'm sorry. 1006. Thank you. Dr. Braasch,
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`could you turn to Exhibit 1003 which is your
`
`declaration. Specifically turn to paragraph 32. And
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`could you please read paragraph 32? It's on page 16.
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` MR. FERGUSON: To himself or out loud?
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` MS. BAILEY: Thank you, Brian.
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` Q. Just to yourself, Dr. Braasch.
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` A. Okay.
`
` (Pause.)
`
` A. Okay. I've read through paragraph 32.
`
` Q. Great. Thank you. So the last sentence on
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 16
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`page 16 of paragraph 32 states, "Furthermore
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`electronic charts may be used with appropriate
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`navigation software to enable a mariner to plot
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`courses sufficiently."
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` Could you explain to me how the electronic
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`charts are used with the navigation software to
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`enable a mariner to plot the courses sufficiently?
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` A. One example is described elsewhere in my
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`declaration and in the prior art that I've analyzed
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`which is the ECDIS system that uses the electronic
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`charts. But also enables the mariner to plan a route
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`and then monitor and log the position of the ship as
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`it's traversing around.
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` Q. So, I'm trying to get an idea of what the
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`marine does in using the electronic chart to plot its
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`route.
`
` Could you kind of walk me through a, let's
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`just say the broad steps of how the mariner would use
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`the electronic chart to plot the route?
`
` (Pause.)
`
` A. The teachings of de Jong and Tetley
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`indicate that the process involves, for example,
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`starting with the point of departure, determining the
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`destination and then considering a number of
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`additional factors that are described in more detail
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 17
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`in the references.
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` But, for example, de Jong talks about the
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`time required, the characteristics of the waterways
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`the ship will be potentially going through and how
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`that may impact the, either the route that's selected
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`or the candidate route that's selected. And de Jong
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`goes through that in great detail as he describes in
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`part a method for planning a route that could be used
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`within the, an algorithm for route planning that
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`could be used within ECDIS.
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` Q. So outside of the teachings of de Jong if
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`the mariner was going to use an electronic chart with
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`navigation software to plot a course, what's the
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`first thing the mariner would do to plot that course?
`
` MR. FERGUSON: Object to the form.
`
` A. The opinions that I have provided in my
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`declaration were focused on de Jong and the
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`combination of de Jong with Tetley. So I have not
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`opined on a situation where de Jong was not being
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`utilized.
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` Q. In paragraph 32 you state that "electronic
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`charts may be used with appropriate navigation
`
`software to enable a mariner to plot courses
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`efficiently."
`
` All I'm asking is how would a mariner plot
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 18
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`the course efficiently per what you stated in
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`paragraph 32 of your declaration?
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` A. One example would be if the mariner has set
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`a particular heading and is intending to sail in a
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`particular direction with a certain heading.
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` What the combination of the electronic
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`navigation charts and the navigation software would
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`enable the mariner to do would be to see the position
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`of the vessel depicted on the electronic chart and an
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`indication of the direction of travel of the vessel.
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` And that is facilitated by the fact that
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`the charts are already in the computer, and with the
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`navigation system that includes a positioning
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`component and an indication of the direction of
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`travel, then that could be depicted on the display of
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`the chart and the position of the vessel and the
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`direction of travel. That can all be done on the
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`computer rather than the mariner by hand having to
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`take a paper chart, put the position of the vessel on
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`the chart and then carefully draw out the line that
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`corresponds to the current course or heading of the
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`vehicle, vessel, for example.
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` Q. Does the mariner plot the course while it's
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`traveling the course and can see its position on the
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`electronic chart?
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 19
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` (Pause.)
`
` A. Could you repeat the question back to me?
`
` MS. BAILEY: Mr. Barton, could you please
`
`repeat the question.
`
` (Record read by the Court Reporter.)
`
` A. That's certainly one example. Mariners do
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`log position as the vehicle is traversing around.
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` Q. Is it plotting the course when it sees the
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`position on the electronic chart?
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` A. I think there are examples of mariner
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`plotting the course, plotting the position of the
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`vessel as it's traversing a given route. There's
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`also examples where the term is used to plot out an
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`intended course.
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` Q. Explain to me how you would plot out an
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`intended course per paragraph 32 of your declaration
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`and the sentence we've been discussing.
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` A. I gave an example earlier where a course
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`might be a given heading from a current or some
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`initial position. And as I mentioned, described
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`earlier, the electronic charts in conjunction with
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`the navigation system can provide a graphical
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`indication of the initial point and that direction of
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`travel.
`
` Q. Let's talk about ECDIS. Explain to me what
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 20
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`ECDIS does.
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` (Pause.)
`
` A. In my declaration I provide an overview of
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`what ECDIS does. In, for example, my paragraphs 35
`
`through 39. And there is quite a bit of additional
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`disclosure provided both in the de Jong and Tetley
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`references.
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` Q. Could you give me a summary of what ECDIS
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`does?
`
` A. Well, sitting here today I'm not sure I can
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`give you a comprehensive summary. But I can
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`certainly give you some examples of some of the
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`functionality in ECDIS.
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` So, for example, in my paragraph 35 and
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`quoting from Tetley that ECDIS is a navigational
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`information system comprising hardware, display
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`software and official vector charts and must conform
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`to the ECDIS performance standards.
`
` In my paragraph 36 quoting from the IMO
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`resolution stating that ECDIS should assist the
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`mariner in route planning and route monitoring, and
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`if required display additional navigational related
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`information.
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` In paragraph 37 I state among some of the
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`many minimum requirements of ECDIS is the ability of
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 21
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`the system to show the ship's position on the
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`display.
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` In paragraph 38 stating that functions such
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`as route planning and route monitoring are enabled by
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`ECDIS along with indications and alarms.
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` As I indicate in paragraph 39 along with
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`certainly the de Jong reference in the late nineties,
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`early 2000s, there was work to enhance ECDIS in order
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`to provide automated support tools for voyage
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`planning. And there's, as I said there's other
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`disclosure that may come to mind in the references as
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`well.
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` Q. What does an ECDIS system look like on a
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`vessel? If I were to walk in and I'm a mariner and I
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`see the ECDIS system, what does it look like?
`
` MR. FERGUSON: Object to the form.
`
` (Pause.)
`
` A. There are a number of examples that are
`
`shown in Tetley. For example, I direct your
`
`attention to Bates page 75 of the Exhibit 1006. And
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`what's being illustrated there is a console of the
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`voyager system produced by Furuno. This is an
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`example of so-called integrated bridge system, and
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`the ECDIS is a part of that.
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` There are additional examples. So if we go
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`Fax: 314.644.1334
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 22
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`to Bates page 77 in 1006 it shows that the ECDIS
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`display is a component of voyager. And I think there
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`are some other examples in Tetley as well.
`
` Q. Okay. Thank you. Why don't we take a
`
`ten-minute break.
`
` MR. FERGUSON: Sure.
`
` MS. BAILEY: Great. Off the record. Thank
`
`you.
`
` (Whereupon, a recess was taken from 10:27
`
`a.m. to 10:41 a.m.)
`
` Q. Welcome back, Dr. Braasch.
`
` A. Thank you.
`
` Q. Outside of de Jong who is doing the route
`
`planning when using an ECDIS system?
`
` MR. FERGUSON: Object to the form.
`
` (Pause.)
`
` A. So the question is outside of de Jong who
`
`is doing the route planning in the ECDIS system. And
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`one example is that the mariner could use the ECDIS
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`system as a simple replacement of the paper chart.
`
`Meaning that the mariner could look at the electronic
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`navigation charts and then by hand, so to speak,
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`determine waypoints on an intended route and do that
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`in conjunction with placing those waypoints on the
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`electronic chart display in ECDIS.
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`Fax: 314.644.1334
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 23
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` One example is the mariner plotting out the
`
`intended course by hand in ECDIS. Whereas de Jong is
`
`suggesting that teaching that the automated tools can
`
`be put into ECDIS in order to automate certain
`
`aspects of the route planning process.
`
` Q. You said the mariner charting by hand, and
`
`I'm summarizing, is one example. What is another
`
`example?
`
` A. I don't have any others coming to mind
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`right here as I sit here today.
`
` Q. Okay. Could you please look at Tetley
`
`which is Exhibit 1006 and look at page 107. Once you
`
`turn to that page let me know, please.
`
` A. I am on Bates page 107 of Exhibit 1006.
`
` Q. Could you please review and read to
`
`yourself bullet point 3 beginning with, electronic
`
`chart display and information system.
`
` (Pause.)
`
` A. I have read the bullet.
`
` Q. Could you turn to the next page of Tetley,
`
`page 108, and read bullet point 8 that begins, route
`
`planning.
`
` (Pause.)
`
` A. I have read that bullet.
`
` Q. Are these two sections that you just read
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`Fax: 314.644.1334
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 24
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`consistent with your understanding and the answer you
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`just gave that a mariner would use ECDIS to plot a
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`course or a route?
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` A. As the reference states ECDIS, I'm quoting
`
`from the end of the bullet that is labeled Electronic
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`Chart Display and Information System, it says at the
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`end of that paragraph, "The ECDIS is used in
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`conjunction with navigation sensors to assist the
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`mariner in route planning, route monitoring and
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`displaying additional navigational related
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`information if required."
`
` So the ECDIS is certainly assisting the
`
`mariner in route planning.
`
` Q. Does ECDIS include route planning?
`
` (Pause.)
`
` A. For example, looking at Bates page 76 of
`
`1006 Tetley states the main features of the ECDIS
`
`are, and numerous bullet points are listed. Bullet
`
`point number 4 is route planning and route
`
`monitoring.
`
` Q. What is meant by the route planning
`
`referred to in the bullet point that you just quoted
`
`from?
`
` (Pause.)
`
` A. As I stated earlier, at least one example
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`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`MICHAEL S. BRAASCH PhD 10/16/2017
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`Page 25
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`is where the ECDIS enables the mariner to specify
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`waypoints of an intended route on the chart. And
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`that's one of the capabilities that ECDIS has. That
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`would be one example that's coming to mind
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`immediately of how ECDIS supports route planning.
`
`And again, this is under the assumption tha