UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` ZIMMER BIOMET HOLDINGS, INC.,
` Petitioner,
` v.
` FOUR MILE BAY, LLC,
` Patent Owner
` Case IPR2016-00012
` Patent 8,821,582 B1
`
` DEPOSITION OF JAY M. VINCELLI, MSc, PE
` Providence, Rhode Island
` Tuesday, October 11, 2016
`
`Reported by: Dana Welch, LCR, CSR, RPR, CRR, CRC
`Job No: 113970
`
`TSG Reporting - Worldwide - 877-702-9580
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`ZIMMER EXHIBIT 1019
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`Page 1 of 49
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`Page 3
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`A P P E A R A N C E S:
`CONLEY ROSE
`Anticipated Successor Lead Counsel for Patent
`Owner Four Mile Bay
`1001 McKinney Street
`Houston, TX 77002
`BY: CHARLES ROGERS, ESQ.
`
`PAUL HASTINGS
`Attorneys for Petitioner Zimmer Biomet
`Holdings, Inc.
`200 Park Avenue
`New York, NY 10166
`BY: YOUNG PARK, ESQ.
`
`- AND -
`
`875 15th Street Northwest
`Washington, DC 20005
`BY: PAROMITA CHATTERJEE, ESQ.
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`Page 2
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` October 11, 2016
` 9:09 a.m.
`
` Deposition of JAY M. VINCELLI, MSc, PE,
`held at the offices of Locke Lord, One Financial
`Plaza, Suite 2800, Providence, Rhode Island, before
`Dana Welch, Registered Professional Reporter, Certified
`Realtime Reporter, Certified Livenote Reporter, and
`Notary Public of the State of Rhode Island.
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`Page 4
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` VINCELLI
` P R O C E E D I N G S
` JAY M. VINCELLI, MSc, PE, sworn
` EXAMINATION
` BY MS. CHATTERJEE:
` Q. Hello, Mr. Vincelli.
` A. Hello.
` Q. Can you please state your name and address
` for the record.
` A. Yes. My name is Jay Michael Vincelli. My
` address is 446 Wakefield Street in West Warwick,
` Rhode Island, 02893.
` Q. Have you been deposed before?
` A. I have.
` Q. How many times?
` A. Twice.
` Q. Were any of those cases patent cases?
` A. No.
` Q. Can you describe the cases in which you've
` been deposed?
` A. Yes. Both cases were regarding products
` liability cases involving metal-on-metal hips, and
` I performed wear measurements on the failed hips
` and testified regarding my measurements.
` Q. And who were the parties in those cases?
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` VINCELLI
` A. Both were for Wright Medical Technologies.
` Q. Were you a witness for Wright Medical?
` A. No. I was a witness for the plaintiffs.
` Q. Who were the plaintiffs?
` A. Um, they were Christiansen and Tucker.
` Q. And were you an expert in those cases?
` A. Yes.
` Q. When was the last time you were deposed?
` A. October 16th, 2015.
` Q. Have you testified at trial before?
` A. No.
` Q. So you are generally familiar with the
` rules of a deposition?
` A. Generally, yes.
` Q. You understand that you're under oath
` today?
` A. Yes.
` Q. Like you would be in a court of law?
` A. Yes.
` Q. And I'm going to ask you questions and
` your answers are going to be transcribed.
` Do you understand that?
` A. Yes.
` Q. Please allow me to complete my questions
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` VINCELLI
` before you respond.
` Do you understand that?
` A. Yes.
` Q. If something is not clear, will you let me
` know?
` A. Yes.
` Q. If you answer, we will assume that you
` understand the question; is that fair?
` A. Yes.
` Q. Your lawyer may object, but you'll need to
` answer the question anyway unless he instructs you
` not to object [sic].
` Do you understand that?
` A. Yes.
` Q. And let's try and have one speaker at a
` time as it's a written record, so we can make it
` easier for the court reporter.
` Do you understand that?
` A. Yes.
` Q. We will take breaks, but if I have a
` question pending, I will ask that you answer the
` question; is that fair?
` A. Yes.
` Q. Do you have any questions?
`
`Page 8
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` VINCELLI
` Q. How long did you prepare?
` A. Um, on the order of about ten hours.
` Q. Did you talk with anyone to prepare for
` your deposition?
` A. Yes. I met with Charles Rogers yesterday.
` Q. Aside from Mr. Rogers, did you speak with
` anyone else?
` A. No.
` Q. And prior to preparing for this
` deposition, how much time have you spent on this
` matter?
` A. I don't know the exact number, but it
` would be on the order of about 50 hours.
` Q. And you mentioned you met with Mr. Rogers
` in preparation for your deposition.
` A. Correct.
` Q. How long did you spend with Mr. Rogers?
` A. About three hours.
` Q. And when did you substantively begin
` working on this proceeding?
` A. To the best of my recollection, it was
` about June of this year.
` Q. And you have prepared a declaration in
` this proceeding?
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` VINCELLI
` A. No.
` Q. Is there any reason you cannot testify
` completely and accurately today?
` A. No.
` Q. Did you bring anything to help you?
` A. I did.
` Q. What did you bring?
` A. I brought a copy of my CV, my declaration
` in this case, the '582 patent, the '550 patent by
` Rostoker, R-o-s-t-o-k-e-r, the '285 patent by
` Zolman, Z-o-l-m-a-n, and a journal article by
` Bobyn, B-o-b-y-n, entitled "Characteristics of bone
` ingrowth and interface mechanics of a new porous
` tantalum biomaterial."
` Q. Did you bring anything else?
` A. And a second copy of my CV in case you
` didn't have one.
` Q. Thank you. Do you have notes on these
` documents?
` A. No.
` Q. What did you do to prepare for the
` deposition?
` A. I reread my declaration. I reviewed the
` documents I brought with me today.
`
`Page 9
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` VINCELLI
` A. I have.
` Q. How long did you spend preparing the
` declaration?
` A. It was on the order of about 50 hours.
` Q. And you're being compensated for your time
` on this matter; is that correct?
` A. Yes.
` Q. What is your hourly rate?
` A. It is about $450 per hour.
` Q. Did you review your declaration in
` preparation for the deposition?
` A. Yes.
` Q. Is there anything you'd like to change or
` clarify?
` A. No.
` Q. When were you first contacted about this
` case?
` A. Either late May or early June of this
` year.
` Q. And how were you contacted for this case?
` A. To the best of my recollection, I received
` a phone call from Philip Lyren, L-y-r-e-n.
` Q. Were you retained before you received that
` phone call from Philip Lyren?
`
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` VINCELLI
` A. No.
` Q. Had you heard of Mr. Lyren before he
` contacted you?
` A. No.
` Q. Aside from Mr. Lyren, was anyone else from
` FMB part of your initial conversations?
` A. No.
` Q. Can you tell me what you recall from your
` initial conversation with Mr. Lyren?
` A. From what I can recall, he discussed he
` had a patent case that was -- that had an Inter
` Partes Review, and he asked me about my
` qualifications and we discussed them. And then he
` sent me the relevant documents to see if I was
` comfortable with the material and qualified to
` render opinions regarding the material. And then
` he retained me.
` Q. When did he retain you?
` A. I don't recall the exact date.
` Q. Did he retain you after your conversation
` with him --
` A. Yes.
` Q. -- discussing your qualifications?
` Have you had any subsequent discussions
`
`Page 12
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` VINCELLI
` Q. Did Mr. Lyren inform you that he is part
` of Four Mile Bay?
` A. Yes.
` Q. Had you heard of Four Mile Bay before this
` proceeding?
` A. No.
` Q. What is your understanding of Four Mile
` Bay?
` A. My understanding is that they own the '582
` patent.
` Q. Are you aware if they own any other
` patents?
` A. I may have seen another patent in the
` references in the '582 patent. Yeah, it references
` application number ending in '642, and also '069.
` Q. Have you reviewed the '642 patent?
` A. I may have, but I didn't take notes on it.
` Q. Have you reviewed the '069 patent
` application?
` A. Briefly.
` Q. What does FMB do?
` A. I don't know, aside from owning the
` patent.
` Q. Are you aware if FMB has any commercial
`
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` VINCELLI
` with Mr. Lyren?
` A. A handful, yes.
` Q. Do you know how many?
` A. I don't.
` Q. Do you recall how many conversations you
` had with Mr. Lyren before he retained you?
` A. I don't. One, maybe two.
` Q. In your initial conversations with
` Mr. Lyren before you were retained -- before he
` retained you, did Mr. Lyren inform you that he was
` an inventor on the '582 patent?
` A. Yes.
` Q. Did Mr. Lyren describe his invention to
` you?
` A. Yes.
` Q. Can you tell me what you recall from that
` conversation?
` A. It was several months ago; I don't recall
` the details.
` Q. Do you recall how Mr. Lyren described his
` invention?
` A. From that conversation, no. I think my
` subsequent review of the patent may cloud whatever
` memory I have of the discussion.
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`Page 13
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` VINCELLI
` products?
` A. I'm not aware.
` Q. Besides this IPR, have you done any other
` consulting work for FMB?
` A. No.
` Q. Aside from Mr. Lyren, have you spoken with
` any other employees of FMB?
` A. No.
` Q. Have you consulted for FMB in any
` litigation involving the '582 patent?
` A. No.
` Q. When I refer to "FMB," you understand that
` I'm referring to Four Mile Bay?
` A. Yes.
` Q. Are you aware that FMB has also retained
` Dr. Michael Helmus for this IPR proceeding?
` A. I am now. I was informed this week.
` Q. Have you reviewed the declaration of
` Mr. Michael Helmus?
` A. I have.
` Q. Is there anything you disagree with in his
` declaration?
` A. I have done a cursory review. I don't
` have anything to disagree with at this time, but it
`
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` VINCELLI
` was not an in-depth review.
` Q. When did you review Dr. Helmus'
` declaration?
` A. I believe it was Thursday of last week.
` Q. Did it seem similar to your report?
` A. Yes.
` Q. Are you aware that Dr. Helmus was deposed?
` A. Yes.
` Q. Have you reviewed the deposition
` transcript?
` A. I have.
` Q. Is there any testimony that you disagree
` with?
` A. It was a long deposition. I don't recall
` anything I disagree with, but I would need to
` review it in more detail to give a more accurate
` answer.
` Q. When did you review the deposition
` transcript?
` A. Also Thursday of last week.
` Q. How long did it take you to review the
` deposition transcript?
` A. I think I spent approximately two hours
` reading it.
`
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` VINCELLI
` would disclose work product communications.
` MR. PARK: Counsel, it either does or
` doesn't reveal work product communications --
` MR. ROGERS: I'm going to ask you to not
` interrupt this deposition. This is a deposition
` treated as trial, one attorney, one witness, and
` I'd ask you to go ahead and work on your --
` whatever you're working on and not interrupt the
` deposition.
` MR. PARK: You're actually incorrect about
` that. In trial it's not one attorney, one witness.
` So your statement there is actually incorrect.
` MR. ROGERS: I'm going to ask you again to
` keep your comments to yourself and stop
` interrupting the deposition.
` MS. CHATTERJEE: I would ask that counsel
` refrain from sidebar comments.
` MR. ROGERS: I agree. You can direct that
` to your colleague.
` MR. PARK: Ask the question.
` Q. Have you discussed the transcript of the
` deposition of Dr. Michael Helmus with your
` attorneys? Yes or no.
` MR. ROGERS: Same objection.
`
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` VINCELLI
` Q. Have you discussed the deposition
` transcript with any of your attorneys?
` MR. ROGERS: Objection to the extent the
` question calls for a disclosure of work product.
` Q. You can answer the question.
` MR. ROGERS: Well, not if his answer
` discloses work product information.
` Q. You can answer yes or no.
` A. I've been directed not to answer that
` question.
` Q. You can answer yes or no as to whether
` you've discussed the transcript with your
` attorneys.
` MR. ROGERS: You're asking for the subject
` of work product communications, so it is proper for
` him to not answer.
` MR. PARK: Are you instructing him not to
` answer?
` MS. CHATTERJEE: Are you instructing him
` not to answer?
` MR. ROGERS: I'm instructing him not to
` answer to the extent that the answer would reveal
` work product communications, which includes the
` subject matter of discussions which inherently
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` VINCELLI
` A. I've been instructed not to answer that
` question.
` Q. Have you discussed the deposition -- the
` transcript of the deposition of Dr. Michael Helmus
` with Mr. Lyren in his capacity as an inventor?
` A. No.
` Q. Have you had any conversations with
` Dr. Michael Helmus?
` A. No.
` MS. CHATTERJEE: At this time I'm going to
` hand to the witness a document that's been marked
` as Exhibit 2051, newly marked. It is Exhibit A
` that was attached to Exhibit 2046, which has not
` been filed in this case.
` Is that a correct representation?
` MR. ROGERS: If you're asking me, yes.
` Q. I'd like to focus on your educational
` background. You have a bachelor's in material
` science and engineering; is that correct?
` A. Yes.
` Q. And this was obtained from the University
` of Florida?
` A. Yes.
` Q. You obtained that degree in May of 2007?
`
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` VINCELLI
` A. Correct.
` Q. And you have a master's in engineering
` sciences?
` A. Correct.
` Q. That's from Dartmouth College?
` A. Yes.
` Q. And you obtained that degree in June of
` 2013?
` A. Yes.
` Q. Did you take any physiology courses as an
` undergraduate student?
` A. I don't recall all the classes that I took
` in college. I know physiology is generally covered
` in some of the classes I've taken.
` Q. Have you taken any biology classes as an
` undergraduate?
` A. I don't believe so. I've taken some
` chemistry classes which relates to biology.
` Q. Did you take any anatomy classes while --
` as an undergraduate?
` A. I don't believe so.
` Q. Did you take any biomedical engineering
` courses as an undergraduate?
` A. Specific courses, no, but biomedical
`
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` VINCELLI
` A. To the best of my recollection, it would
` have been ultra-high-molecular-weight polyethylene,
` and also PEEK.
` Q. Any others?
` A. I don't believe so.
` Q. And what are those materials used for in
` orthopedic applications?
` A. Ultra-high-molecular-weight polyethylene
` is used as a bearing material in hips and knees and
` shoulder implants, and PEEK is used in spinal
` applications.
` Q. And what do you mean by "bearing
` materials"?
` A. In hip implants, for instance, there are
` two components: A femoral head and an acetabular
` cup. And inside the cup they would put the
` ultra-high-molecular-weight polyethylene to
` articulate against the femoral head, and in that
` instance it's used as a bearing material.
` Q. So the femoral head articulates against
` the bearing material?
` A. Both are bearing materials; they bear
` against each other.
` Q. Can you make a femoral head using that
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` VINCELLI
` engineering was covered in some of the classes that
` I did take.
` Q. What classes were those?
` A. I took a polymer course where we talked
` about different types of polymers, including those
` used in biomedical engineering. And I've taken
` classes on -- metallurgy classes that also involved
` discussing metals used in biomedical engineering.
` Q. Did you discuss specific clinical
` applications in those courses?
` A. I believe so, yes.
` Q. In your polymer course, did you discuss
` materials used for orthopedic applications?
` A. I believe so, yes.
` Q. Did you look at any commercial orthopedic
` devices in your polymer course?
` A. Physically, no, but I believe we were
` shown some either in our textbook or during
` lecture.
` Q. And what type of polymers did you study
` that related to orthopedic --
` MS. CHATTERJEE: Strike that.
` Q. What type of polymers did you study that
` was used in orthopedic applications?
`
`Page 21
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` VINCELLI
` material?
` A. It's not commercially done.
` Q. And in your polymer class, did you learn
` or study anything on coatings in orthopedic
` applications?
` A. I don't believe so.
` Q. You mentioned you took a metallurgy class.
` A. Yes.
` Q. In your metallurgy class, did you look at
` any commercial orthopedic devices?
` A. I believe so, but it was over a decade
` ago. It's difficult to recall the details.
` Q. In your metallurgy class, did you discuss
` any materials that are used for orthopedic
` applications?
` A. I believe so, yes.
` Q. What are those materials?
` A. Titanium and titanium alloys, cobalt
` chrome. We also likely discussed nitinol,
` n-i-t-i-n-o-l, and maybe others.
` Q. And what are those materials used for?
` A. Titanium is used in several applications.
` It's used as the material for hip stems. It's also
` used as the backing material for the acetabular
`
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` cup. I believe they also may make some bone plates
` out of them.
` For cobalt chrome, it's used as -- they
` also make some hip stems out of cobalt chrome. And
` the bearing material for the femoral head is made
` out of cobalt chrome. And in metal-on-metal hip
` applications, the acetabular cup is also made out
` of cobalt chrome. And in knee implants as well,
` some of the components are made out of cobalt
` chrome.
` And for nitinol, it's used in venous
` catheters -- I'm sorry -- venous filters.
` Q. And you referred to a hip stem.
` A. Yes.
` Q. What is a hip stem?
` A. A hip stem is a component in a hip
` replacement system and it is placed into the femur
` and the femoral head is mounted to that stem.
` Q. And in your metallurgy class, did you
` discuss tantalum?
` A. Possibly.
` Q. Earlier you mentioned that the femoral
` head is mounted onto the hip stem; is that correct?
` A. Yes.
`
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` of hip implant systems.
` Q. And during your metallurgy class in
` undergrad, did you see any commercial hip implants?
` A. Physically, no.
` Q. Did you review brochures of any commercial
` hip implants?
` A. At the time, I don't believe so.
` Q. Did you study what was on the market
` during your course?
` A. During my course, no.
` Q. How do you know that the head was impacted
` onto the stem in hip implants at that time?
` A. Your earlier question I didn't believe was
` referring to my knowledge at the time. I thought
` you were asking in general how hip implants were
` made.
` Q. So during your metallurgy class, did you
` not discuss how a hip implant was put together?
` A. I don't believe so.
` Q. Did you take any other courses related to
` the design of hip implants during your
` undergraduate program?
` A. I don't believe so.
` Q. Did you do any research projects while at
`
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` Q. What does "mounted" mean?
` A. It is -- for modular systems, there is a
` neck and the femoral head is impacted onto the
` neck, and that's how it's mounted onto the stem.
` Q. When you refer to "modular systems," what
` do you mean by modular systems?
` A. Where the femoral head is a separate
` component from the hip stem.
` Q. And what does "impacted" mean?
` A. Hit with a mallet.
` Q. To create a tight fit?
` A. Correct.
` Q. During your course, did you see a modular
` system with a separate femoral head and hip stem?
` A. I don't believe so.
` Q. Since then, have you seen a modular system
` with a separate femoral head and hip stem?
` A. Yes.
` Q. And in what products?
` A. Many products. I'm sure we will get to my
` experience at Dartmouth College where we can talk
` about that some more. I've seen hundreds of hip
` implants. And as part of my thesis, I reviewed the
` history of orthopedic implants, so I've seen a lot
`
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` the University of Florida?
` A. I did.
` Q. Can you describe those?
` A. Yes. I worked at the Particle Engineering
` Research Center and I worked on two different
` projects: One was studying the nucleation and
` growth of kidney stones and the effect of a
` compound on the nucleation and growth of those
` crystals. And I also worked on a project to
` develop a new material for a smokescreen for the
` military.
` Q. So you did not do any research on hip
` implants while at the University of Florida?
` A. I did not.
` Q. Did you take any physiology courses in
` graduate school?
` A. I did not.
` Q. Did you take any anatomy courses in
` graduate school?
` A. I did not. But both physiology and
` anatomy were discussed in various classes.
` Q. Did you take any coursework related to the
` design of orthopedic implants --
` A. Yes.
`
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` Q. -- in graduate school?
` A. (Nodding head up and down.)
` Q. What were those courses?
` A. I don't recall the exact name of the
` courses. One of them may have been -- I'm sorry.
` I don't recall the names of the courses.
` Q. How many courses did you take that relate
` to the design of orthopedic implants?
` A. On the order of four, yeah.
` Q. Can you briefly describe the subject
` matter of those four courses?
` A. Let's see, one of the classes was
` regarding just all types of medical devices where
` we talked about -- including hip implants and the
` various designs, and it also included surgical
` tools that are used to install the implants.
` I had another course where the main
` project, anyway, was developing a new medical
` device. And I invented a miniaturized
` cardiopulmonary bypass circuit that was intended to
` be used for studying the side effects of being put
` on bypass by using this machine on mice. And I
` can't recall the other courses at this time.
` Q. In the course where you discussed various
`
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` Q. In those implants you reviewed, do you
` know when those implants were made available?
` A. No.
` Q. Do you know if those hip implants were
` made available commercially?
` A. Yes.
` Q. When?
` A. I'm -- I'm not certain.
` Q. How do you know that they were commercial
` products?
` A. They were failed hip implants.
` Q. Do you know when they were implanted?
` A. The ones I saw in the class, no.
` Q. Can you describe those implants?
` A. I believe we looked at both metal-on-metal
` and metal-on-polymer hip implants.
` Q. You referred to metal-on-metal hip
` implants. What is a metal-on-metal hip implant?
` A. A metal-on-metal hip implant is where both
` bearing materials are made of metal and both metals
` are cobalt chrome.
` Q. Can you have a metal-on-metal hip implant
` with titanium?
` A. No. Not as a bearing surface.
`
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` designs of medical devices, did you discuss hip
` implants?
` A. Yes.
` Q. Did you review commercial hip implants in
` that course?
` A. Yes.
` Q. When did you take that course?
` A. Approximately in 2012.
` Q. Do you remember which commercial hip
` implants you reviewed?
` A. Specifically, no. I believe it was
` multiple devices.
` Q. What components of the hip implants did
` you review?
` A. The ones I've mentioned so far, which
` include the hip stem; sometimes the neck is also
` modular, so we discussed modular necks; the femoral
` head; the acetabular cup, and the various liners
` they can put inside the cup, which include
` polyethylene, cobalt chrome and different ceramics.
` Q. Did you review the physical implants
` themselves?
` A. I believe an example was provided in that
` class.
`
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` VINCELLI
` Q. Can you have other portions of the hip
` implant be made of titanium?
` A. Yes.
` Q. And what portions are those?
` A. The hip stem and also the acetabular cup.
` Q. Did you look at the coatings on those hip
` implants?
` A. Yes.
` Q. What type of coatings were on those hip
` implants?
` A. It's my recollection they were
` plasma-sprayed titanium beads.
` Q. On what component of the hip implant were
` they located?
` A. On both the acetabular cup and also on the
` hip stem.
` Q. Do you know who the manufacturer was of
` those implants?
` A. That we saw in the class, I don't recall.
` Q. You mentioned you took a design course.
` A. Yes.
` Q. You mentioned you designed a pulmonary
` bypass circuit. Was that in a design course?
` A. Yes.
`
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` Q. And did you review general parameters for
` designing a medical device in that course?
` A. I don't recall.
` Q. Can you describe the subject matter,
` general subject matter of the course?
` A. I'm trying to remember, but I just
` remember the project that we did in that class.
` But I know we also talked about various imaging
` techniques. We did some programming, looking at
` the heating of lasers that are used to treat
` tumors. That's about all I can recall from the
` class at this time.
` Q. Have you in your coursework at Dartmouth
` designed a hip implant?
` A. During my coursework, no. As part of my
` research, I developed a surgical tool used on hip
` implants.
` Q. And going back to your undergraduate
` degree, have you looked at coatings, porous
` coatings during your undergraduate degree?
` A. I may have. I don't recall.
` Q. Did you study porous coatings during your
` graduate school as part of your coursework?
` A. Yes.
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` VINCELLI
` A. I believe so, yes.
` Q. And are there any characteristics that a
` designer should look at when constructing those
` porous materials?
` A. Can you define "constructing"?
` Q. Fabricating the porous structures.
` A. So it depends on the type of porous
` structure. For sintered beads, for instance, you'd
` look at the velocity of the beads that you're
` plasma spraying on the surface, the temperature,
` the size of the beads.
` Q. And in methods for roughening the surface,
` what characteristics would you look for when
` constructing the porous coating?
` A. You look at surface roughness, and maybe
` some others as well, but primarily surface
` roughness.
` Q. And for the kinked wire coatings, what
` design parameters would a designer consider when
` constructing a kinked wire coating?
` A. During fabrication you'd look at the
` pressure that you're using to compress the wires,
` potentially temperature as well.
` Q. And for the TM coatings, what design
`
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` Q. What types of coatings?
` A. The various coatings that are put on hip
` implants.
` Q. And what were those?
` A. There are a couple of different types.
` There are titanium beads that I mentioned earlier.
` There were methods for roughening the surface of
` the implant which aids in promoting bony ingrowth.
` There are also kinked wire coatings, and also
` coatings called trabecular metal.
` Q. What course did you study these coatings
` for?
` A. That was -- I believe it was the first
` course I mentioned that talked about all the
` different types of medical devices.
` Q. Do you remember what the course title was?
` A. I'm trying, but unfortunately I can't
` remember.
` Q. And as part of that course, did you study
` what attributes are required to construct those
` porous coatings?
` A. Can you be more specific?
` Q. For that course, did you study how to
` construct those porous materials?
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` parameters did you consider when constructing a TM
` coating?
` A. I don't recall the specifics at this time
` for what we discussed in that class.
` Q. Are there any design parameters that are
` important for designing a porous structure?
` A. Yes.
` Q. And what are those?
` A. In general, you look at the porosity, how
` that porosity is constructed, whether it's open
` porosity or closed porosity, pore size, and the
` shape and structure of the coating itself and also
` the material.
` Q. In your course that we've been describing,
` did you study natural human bone?
` A. I believe so, yes.
` Q. And in this coursework, did you study the
` cellular structure of natural human bone?
` A. I believe so, yes.
` Q. What type of bone?
` A. To my recollection, we were talking about
` the femur.
` Q. So it was in the context of orthopedic
` applications?
`
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` A. Yes.
` Q. And did you inspect an actual human bone?
` A. I have, yes. Not in that course. We had
` a skeleton in our laboratory that was an actual
` skeleton. And also looked at what they call
` Sawbones, which are synthetic versions of bone that
` are used for helping to train surgeons. I had a
` demonstration by DePuy Sy