`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---oOo---
`
`LAM RESEARCH CORP.,
` Petitioner,
`vs. No. IPR2015-01767
`DANIEL L. FLAMM, Patent No. 6,017,221
` Patent Owner.
`_________________________/
`
` DEPOSITION OF DANIEL L. FLAMM, Sc.D.
` OAKLAND, CALIFORNIA
` TUESDAY, JULY 26, 2016
`
`BY: ANDREA M. IGNACIO, CSR, RPR, CRR, CCRR, CLR ~
`CSR LICENSE NO. 9830
`JOB NO. 110249
`
`TSG Reporting - Worldwide 877-702-9580
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`Page 1 of 4
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`Samsung Exhibit 1020
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`Page 23
` Q Reviewing claim 1, is the embodiment shown in
`Figure 4 encompassed in the scope of independent
`claim 1?
` A I think so.
` Q Do you agree that the element labeled 400 in
`Figure 4 is a wave adjustment circuit?
` A I'd have to check and see what the legend
`says, because it refers to an outline, and --
` Q Maybe I can help you.
` If you look at column 16, lines 4 through 6,
`I believe there, it says --
` A 16, lines 4 through 6. I don't -- I must be
`looking at the wrong pages. I don't see a 400 there.
` Oh, here we go. 400. Yeah. Okay. So, it
`evidently refers to the contents of the -- what's
`enveloped by 400.
` Q So, if we read that sentence that starts on
`line 4. Could you read that for me, the first --
` A It starts on line 4?
` Q The sentence.
` A Oh.
` "The helical resonator 126 includes a
`coil 132, an outer shield 133, a wave adjustment
`circuit 400, and other elements."
` Q Could you also look at Figure 2A.
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`TSG Reporting - Worldwide 877-702-9580
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`Page 196
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`meant to say an inductively coupled discharge.
` MR. FLEMING: Q. So what if it's selectively
`balanced at, let's say, 1 percent?
` A I -- actually, you know, I'm not sure what
`1 percent means in this context, but we could invent
`something, I'm sure. But, you know, I'd have to
`think -- I'd have to think a great deal. I -- I would
`look to the specification to decide that.
` Q So, in my review of the specification, I
`certainly didn't find anything that --
` A Well, there are --
` Q -- seemed to support selectively balanced.
` Do you have something in mind?
` A I don't have anything in mind as we speak,
`because I haven't gone through the specification. I
`think it mentions selecting. I'd have to find -- I --
`I don't want to -- you know, I -- I declined to do it
`in real time because I'm not -- I'm not confident to
`kind of look at portions on the fly and decide on
`numbers. I don't -- I don't have preconceived numbers
`in mind.
` Q So, selectively balanced has a very vague
`meaning?
` A Well, it's really determined, as you asked
`earlier, by what -- somebody with ordinary skill in
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`TSG Reporting - Worldwide 877-702-9580
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`Page 197
`the art would judge, you know, a boundary as with --
` Q But it --
` A -- respect to the specification.
` Q -- it would appear then, when you say
`10 percent balanced, that that would be covered --
` A That would probably be within the bounds
`of -- with selecting a 10 percent balance would
`probably be within the bounds.
` Q So, the range of 10 percent to 100 percent
`balance would be --
` A Well, we didn't say 100 percent. In fact, we
`almost -- we --
` Q 95 percent?
` A Well, now you're asking the same question in
`a different way. And I explained that I -- I -- you
`know, I'm not prepared to do claim construction right
`now.
` Q Well, but you did say that at 10 percent
`balanced, it would be --
` A Offhand, I think it would be fair to judge
`that if you selected -- you know, so it's a
`substantial distance away. You know, it's a -- so
`totally -- totally balanced, substantially balanced,
`okay, is within the -- within the scope of the claim,
`clearly.
`
`TSG Reporting - Worldwide 877-702-9580
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`Page 4 of 4
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`
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