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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________
` )
`INTUITIVE SURGICAL, INC., )
` )
` Petitioner, ) IPR No.
` ) 2018-01247
` vs. )
` ) U.S. Patent No.
`ETHICON, LLC., ) 8,479,969
` )
` Patent Owner. )
` )
`____________________________________)
`
` DEPOSITION OF SHORYA AWTAR, Ph.D.
`
` Washington, D.C.
`
` June 17, 2019
`
` 9:30 a.m.
`
`REPORTED BY: GOLDY GOLD, RPR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` 1
`
`Exhibit 1019
`Intuitive v. Ethicon
`IPR2018-01254
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________________
` )
`INTUITIVE SURGICAL, INC., )
` )
` Petitioner, ) IPR No.
` ) 2018-01247
` vs. )
` ) U.S. Patent No.
`ETHICON, LLC., ) 8,479,969
` )
` Patent Owner. )
` )
`____________________________________)
`
` DEPOSITION OF SHORYA AWTAR, Ph.D.
`
` Washington, D.C.
`
` June 17, 2019
`
` 9:30 a.m.
`
`REPORTED BY: GOLDY GOLD, RPR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
` 1
`
`Exhibit 1019
`Intuitive v. Ethicon
`IPR2018-01254
`
`
`
`Shorya Awtar, Ph.D. - June 17, 2019
`
`Page 2
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` June 17, 2019
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` 9:30 a.m.
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` Deposition of SHORYA AWTAR, Ph.D., held
`
` at the offices of Weil Gotshal & Manges, 2001 M
`
` Street, NW, Suite 600 Washington, D.C. 20036
`
` before Goldy Gold, a Registered Professional
`
` Reporter and a Notary Public within and for the
`
` State of District of Columbia.
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 3
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`A P P E A R A N C E S:
`
` ON BEHALF OF THE PETITIONER:
`
` FISH & RICHARDSON, PC
`
` BY: STEVEN KATZ, ESQ.
`
` One Marina Park Drive
`
` Boston, Massachusetts 02210
`
` E-mail: katz@fr.com
`
` Telephone: (617) 542-5070
`
` ON BEHALF OF THE PATENT OWNER:
`
` WEIL GOTSHAL & MANGES, LLP
`
` BY: CHRISTOPHER MARANDO, ESQ.
`
` 2001 M Street, NW, Suite 600
`
` Washington, D.C. 20036
`
` E-mail: christopher.marando@weil.com
`
` Telephone: (202) 682-7000
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 4
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` I N D E X
`
` EXAMINATION
`
`WITNESS PAGE
`
`SHORYA AWTAR, Ph.D.
`
` By Mr. Katz 5
`
` ******
`
` E X H I B I T
`
`PETITIONER EXHIBITS DESCRIPTION PAGE
`
`Exhibit 1020 U.S. Patent 52
`
` No. 9,820,768 B2
`
`Exhibit 1021 Anderson patent 123
`
` with witness' annotations
`
` ******
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 5
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`WHEREUPON,
`
` DR. SHORYA AWTAR
`
`called as a witness, having first been duly sworn by
`
`the Notary Public, was examined and testified as
`
`follows:
`
` EXAMINATION
`
`BY MR. KATZ:
`
` Q. Welcome, Dr. Awtar. Could you please
`
`just state and spell your name for the record?
`
` A. Okay. My name is Shorya Awtar, spelling
`
`S-H-O-R-Y-A, A-W-T-A-R.
`
` Q. All right. And could you just pronounce
`
`your last name one more time?
`
` A. Awtar; it says with a "V" instead of
`
`a "W."
`
` Q. Thank you.
`
` I understand that you've been deposed
`
`before?
`
` A. No, this is my first deposition.
`
` Q. Oh, you have not been?
`
` A. Yes.
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` Q. Well, let me just give you a few helpful
`
`tips to make this go smoothly.
`
` A. Okay.
`
` Q. First of all, any time if I ask a
`
`question you don't understand, please just ask me to
`
`repeat it and/or clarify, and I will do so.
`
` Also, it's very important, because the
`
`court reporter is taking down what we say, that we
`
`not talk over each other. So if you will just wait
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`till I finish the question before you answer, and I
`
`will try to let you finish an answer before I ask my
`
`next question.
`
` A. Okay.
`
` Q. In addition, we'll probably be taking
`
`breaks roughly every once an hour, but more or less
`
`it's all up to you. If at any time you feel you need
`
`a break, just ask.
`
` A. Okay. Thank you.
`
` Q. Also, I ask that you do keep your voice
`
`up. We do have a little bit of air-conditioning
`
`noise in the background, and sometimes the court
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`reporter has a hard time hearing if you start talking
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`softly.
`
` A. Okay. I'll be careful, yes, or mindful,
`
`yeah.
`
` Q. And I don't think it's going to be a
`
`problem, but some experts are extremely fast talkers,
`
`especially when they read. It doesn't sound like
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`that's going to be a problem, but you want to
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`consciously talk slowly enough so that the court
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`reporter can get you.
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` A. I'll try. If I do end up talking faster
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`than what is normal, will one of you let me know?
`
` Q. We will.
`
` A. Thank you.
`
` Q. Also, just so you understand what's
`
`going to be happening, actually there are three --
`
`you have declarations in three different IPR
`
`proceedings related to U.S. Patent 8479969; is that
`
`correct?
`
` A. That is correct, yes.
`
` Q. And we're actually going to be doing
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`three sequential depositions. I've already spoken
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`with counsel for Ethicon, and we're only going to be
`
`focusing today exclusively on the proceeding that is
`
`IPR2018-01247. And then tomorrow we'll be doing
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`depositions for 01248 and then 01254.
`
` A. That's correct. That's my
`
`understanding.
`
` Q. Okay. And so actually that's for the
`
`court reporter's benefit. So even though it's all
`
`really the same patent, we're going to be formally
`
`closing our transcript and reopening a new one, just
`
`as a technicality issue.
`
` All right. So with that, let's begin.
`
` Can you just tell me, at a high level,
`
`what experience that you have, education and
`
`experience that you believe is relevant to the
`
`opinions that you're providing in this case?
`
` A. Sure. A brief overview of my experience
`
`and background was included in the declaration. I
`
`can provide a summary of that. Is there any
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`particular aspect that you may want me to elaborate
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`upon further?
`
` Q. Sure. There seem to be quite a lot of
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`papers. You're very prolific. Congratulations on
`
`that.
`
` A. Thank you.
`
` Q. I assume not everything in your CV
`
`relates directly to evaluating the issues surrounding
`
`the '969 patent. So why don't you just highlight for
`
`me what you think are the most significant
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`educational --
`
` A. Aspects.
`
` Q. Yes, aspects, exactly.
`
` A. Okay. Thank you. So I'm an associate
`
`professor of mechanical engineering at the University
`
`of Michigan. As part of my job at the university, I
`
`conduct research in, as well as I conduct teaching
`
`in, the areas of machine design, mechanism design,
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`robotics, and mechatronics. What this entails is a
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`variety of contraptions, apparatus, that are used to
`
`generate motion, that are used to transmit motion,
`
`that are used in a variety of applications that may
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`range from medical devices, to precision motion
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`stages, to microelectromechanical systems.
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` So the skill set that I mention in
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`machine design, mechanism design, mechatronics, and
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`robotics is a broad skill set. It's sort of a
`
`foundational skill set that, depending on the
`
`application, I bring it to the fore and I apply it to
`
`a given application.
`
` I think your question was more pertinent
`
`to medical devices. So definitely I have applied
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`these skills to medical devices as part of my
`
`research at the University of Michigan.
`
` Subsequent to that -- in fact, I'll
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`describe a bit more my research at the University of
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`Michigan in medical devices.
`
` In 2007, I started collaborating with
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`surgeons at the University of Michigan to develop
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`laparoscopic instruments, affordable laparoscopic
`
`instruments. I worked with several students and
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`staff members of the university to design and develop
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`multiple prototypes of these laparoscopic
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`instruments. And then eventually, I, along with a
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`surgeon cofounder, started the company FlexDex
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`Surgical. And as part of FlexDex Surgical also, I
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`have been putting my skills, the foundational skills
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`that I mentioned earlier, to use in the design and
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`development of laparoscopic instruments.
`
` Q. Just a few questions on that.
`
` When you say associate professor, is
`
`that a tenured position?
`
` A. It is a tenured position, yes.
`
` Q. And so you say you began work in 2007 in
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`laparoscopic instruments?
`
` A. I began at the University of Michigan in
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`2007. My experience with laparoscopic instruments
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`and minimally invasive surgical instruments and
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`robotics goes all the way back to my Ph.D. days
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`where -- my Ph.D., which went from 2000 till 2003,
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`December 2003 -- my Ph.D. -- actually I'll correct
`
`that. Not Ph.D.; the technical name of the degree is
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`Sc.D., doctorate of science, Sc.D. -- my doctorate at
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`MIT was from 2000 till the end of 2003. It was in
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`the area of robotics and mechanisms.
`
` As part of that, once again, I was
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`looking at what are the applications of robotics and
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`mechanisms. Medical devices and medical robotics was
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`an area that I became aware of. I wasn't designing
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`any medical instruments at the time, but I was
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`exploring and investigating that space.
`
` Prior to my Ph.D. -- again, I'm sorry, I
`
`keep using the term Ph.D. Prior to -- I mean post my
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`Sc.D., post my doctorate, I joined General Electric
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`in 2004, January of 2004. For three years while I
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`was there, I had -- the time was given to me to
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`explore and investigate any area of my choice, any
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`application area of my choice.
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` So while I was making use of my skills
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`in mechanical design, machine design, robotics,
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`mechatronics on certain problems that had been
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`assigned to me at GE, at the same time, I was
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`investing a portion of my time investigating medical
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`devices and medical robotics. So that was the period
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`from January 2004 until the end of 2006.
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 13
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` In 2007, when I started at the
`
`University of Michigan, that's when I transitioned
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`from the research mode to actually designing and
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`developing medical devices for laparoscopy.
`
` Q. So, I guess, what you're saying is you
`
`started the design of laparoscopic instruments in
`
`2007, but you had been researching the topic before
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`that?
`
` A. Exactly. Exactly.
`
` Q. When you were researching laparoscopic
`
`instruments from 2002 to 2006, which instruments were
`
`you focused on?
`
` A. I was focused on laparoscopic
`
`instruments. Instruments -- laparoscopic instruments
`
`are handheld instruments that are used in surgery.
`
` What was clear in that time frame was
`
`that in the U.S., there had already been a
`
`significant transition from open surgery to
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`laparoscopic surgery, but outside of the U.S., that
`
`transition was still ongoing.
`
` Also at the same time, there was quite a
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`Page 14
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`bit of buzz associated with surgical robotics because
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`of the DaVinci System that Intuitive had launched.
`
` So that was the landscape. The
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`landscape was that of handheld laparoscopic
`
`instruments, some emerging robotic technologies. It
`
`was the combination, this entire scope of, you know,
`
`the technologies that were available at that time
`
`that I was looking into and just trying to understand
`
`what are the pros and cons, and what are the
`
`limitations and so on of these technologies.
`
` Q. Between 2000 and 2006, did your research
`
`involve investigation of laparoscopic staplers?
`
` A. I wouldn't say laparoscopic staplers in
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`particular. In that phase, it was sort of my initial
`
`exploratory phase in medical devices. I was at that
`
`time looking at just a variety of laparoscopic
`
`instruments. At that point I wasn't differentiating
`
`between a laparoscopic stapler or a laparoscopic
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`needle driver or a grasper.
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` I think I must have come across a
`
`variety of papers and patents that cover these
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`Page 15
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`various instruments tips. But at that point, I
`
`wasn't particularly focused on one kind of instrument
`
`tip.
`
` Q. So what was the nature of the research,
`
`if it wasn't focused on a particular instrument tip?
`
` A. The nature of research was primarily on
`
`how the surgeon's control, surgeon's hand movements,
`
`are transmitted to the tip of a laparoscopic
`
`instrument inside a patient's body.
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` So the research or the investigation was
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`focused more on understanding the mechanics of motion
`
`transmission.
`
` Q. And did you acquire actual laparoscopic
`
`instruments or this was just looking at patents and
`
`publications?
`
` A. This was patents, publications, on-line
`
`videos, images. Oftentimes, companies have
`
`animations on their websites. It was -- it didn't
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`involve my holding, acquiring a laparoscopic -- a
`
`sample laparoscopic instrument.
`
` Q. And was this in formal research or did
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`you generate papers based on it?
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` A. It is hard to qualify research as formal
`
`or informal. What I can answer specifically is that
`
`I did not generate any papers on this. The issue of
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`formal versus informal, I can only add that some of
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`most serious work that I have done, the most
`
`impactful work that I've done, in my own opinion,
`
`started out as an open-ended investigation, as I'm
`
`sure you have seen, you know how researchers come up
`
`with ideas.
`
` Q. And jumping up to 2007, when you started
`
`design work -- strike that.
`
` I understand that your company -- you
`
`described your company as an early stage company?
`
` A. That is right, yes.
`
` Q. Does that mean that you've not formally
`
`released a product publicly yet?
`
` A. We have released a product formally,
`
`publicly. Early stage is simply dictated by metrics
`
`such as how much money has been invested in the
`
`company, the size of the company, the number of
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`Page 17
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`products it has launched, the amount of sales
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`revenues, the number of employees, things like that.
`
` Q. How many products has your company
`
`launched?
`
` A. One.
`
` Q. What is that?
`
` A. The one product that my company FlexDex
`
`Surgical has launched is a purely mechanical,
`
`handheld laparoscopic instrument which is used for
`
`suturing and knot-tying inside the patient's body.
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` Q. Does the instrument articulate?
`
` A. Yes, it's an articulating instrument,
`
`yes.
`
` Q. And what's the name of it?
`
` A. I do not recall the formal name of the
`
`product as it might appear on regulatory documents.
`
`I can guess.
`
` Q. I don't want you to guess. That doesn't
`
`help anyone.
`
` A. Okay.
`
` Q. If I went to your website, would it only
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 18
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`have one product?
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` A. It should. The description of the
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`product is a FlexDex needle driver. That may not be
`
`the formal name of the product, but it is a FlexDex
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`needle driver, and the description is that it's a
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`purely mechanical, handheld laparoscopic instrument.
`
` Q. When you say purely mechanical, what do
`
`you mean by that? What is that excluding?
`
` A. Purely mechanical is an instrument or
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`system or machine that has only mechanical
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`components, such as gears, levers, springs, cables,
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`pulleys. It doesn't include anything that is
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`electrical. So it doesn't include any sensors or
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`actuators or micro-controllers or batteries, power
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`sources, anything like that.
`
` Q. And is the articulation active or
`
`passive?
`
` MR. MARANDO: Object to form.
`
` Go ahead.
`
` A. I can answer that. I just wanted some
`
`clarification. Can you tell me what you mean by
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`active and passive?
`
` Q. I guess I'm not quite an expert in the
`
`field. Those are terms that are in the documents in
`
`this case.
`
` You tell me, what does it mean to be
`
`active versus passive?
`
` A. Okay. So I can provide my
`
`interpretation of those terms.
`
` In the context of a laparoscopic
`
`instrument, active articulation means articulation
`
`that is actively driven and controlled by a user,
`
`which would be the surgeon in this case.
`
` To further elaborate, active would mean
`
`that there would be a certain control input provided
`
`by the user or the surgeon, and that control input
`
`via a sequence of transmissions drive the
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`articulation of the -- of an end effector at the tip
`
`of an instrument. That is how I define active.
`
` Q. So what would passive articulation be?
`
` A. Passive is -- I would say it's -- it
`
`would be perhaps a broader term. Anything that is
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`not active will be passive. Any instance of an
`
`instrument having articulation capability but that is
`
`not actively driven by the surgeon, in the sense that
`
`a control motion of the surgeon produces articulation
`
`of the end effector. Anything that doesn't meet that
`
`criteria, I would put that in the category of
`
`passive, where the surgeon is not actively driving
`
`the articulation of the end effector.
`
` Q. So using those definitions, was the
`
`instrument that you made, that your company designed,
`
`active or passive?
`
` A. It is an active articulation system or
`
`instrument that -- that offers active articulation.
`
` Q. Have you ever in your career designed a
`
`surgical stapler?
`
` A. No, I have not designed a surgical
`
`stapler. And by a surgical stapler, we're
`
`referencing to an endocutter, a linear endocutter,
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`and I haven't designed an instrument like that.
`
` Q. Is your understanding the term
`
`endocutter is a well-known term outside of Ethicon or
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`that a term Ethicon is called?
`
` MR. MARANDO: Object to form.
`
` A. I do not know. I use the term based on
`
`multiple patents that I've read and multiple
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`conversations that I've had with surgeons. And it's
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`based on that that's in forming my terminology. I
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`wouldn't know that term, the linear endocutter, is a
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`term that was coined by Ethicon or by the surgical
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`community.
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`BY MR. KATZ:
`
` Q. Have you ever worked on a -- strike
`
`that.
`
` Have you ever designed a surgical
`
`stapler of any sort?
`
` A. No, I have not designed a surgical
`
`stapler of any sort.
`
` Q. Have you ever designed a robotic system?
`
` MR. MARANDO: Objection to form.
`
` A. A "robotic system" is a very broad term.
`
`Can you specify a bit further? Because a lot of
`
`things are robotic systems.
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`BY MR. KATZ:
`
` Q. Well, yes, I mean have you ever --
`
` A. Is that any robotic system? Is that it?
`
` Q. In your career, have you designed
`
`something you would consider to be a robotic system?
`
` A. Multiple, yes, multiple times.
`
` Q. Was this in a surgical space or in
`
`another space?
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` A. I have evaluated robotic systems in the
`
`surgical space; not designed, but evaluated. I have
`
`designed robotic systems in nonsurgical space in
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`precision motion stages and moving a motion stage
`
`over multiple degrees of freedom via robotic
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`technology, by using robotic technology.
`
` Q. When you say a motion stage, what is
`
`that?
`
` A. Motion stage is a stage that moves along
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`multiple directions. So one example is a robotic
`
`arm. So if you consider the tip of a robotic arm, it
`
`has multiple degrees of freedom. It could translate
`
`and rotate. It could open and close. Those are all
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`multiple degrees of freedom.
`
` A motion stage, similarly, is a stage in
`
`a machine in a robotic system that has multiple
`
`degrees of freedom. And those multiple degrees of
`
`freedom are achieved by a combination of mechanical
`
`design, mechanical structures, sensors, actuators,
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`feedback controls.
`
` Q. So are you saying your design is just a
`
`generic portion of a robot that could move without
`
`regard to a specific use for that robot?
`
` A. No. I mean, I would say there are
`
`specific uses for the robots that I design. These
`
`are robots that would be used, for example, in the
`
`semiconductor industry.
`
` Since your question was, have I designed
`
`a robotic system, and my response was "robotic
`
`system" is just a very broad term, I cited an example
`
`of a robotic system.
`
` Q. And earlier you were talking about
`
`multiple degrees of freedom. If something opens and
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`closes, is that one degree of freedom or two?
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`Shorya Awtar, Ph.D. - June 17, 2019
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` A. It depends. It depends. If there's one
`
`control that dictates the opening -- oh, open and
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`close is one degree of freedom. I'm sorry. Open and
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`close is one degree. It's one control that dictates
`
`the opening, and the same control, control in a
`
`different direction, dictates the closing. And it's
`
`one degree of freedom.
`
` Q. Is there a definition in your mind of
`
`what a degree of freedom is?
`
` A. Yes. A degree of freedom is, broadly
`
`speaking, again in the field of machine design, the
`
`technical subfield of defining degrees of freedom is
`
`called kinematics.
`
` Kinematics is the study of motion
`
`between various bodies. So in the simplest case, you
`
`start with two bodies, and you want to define the
`
`motion of one body with respect to another body. So
`
`in my desire and my pursuit to define the motion of
`
`one body with respect to another body, we try to
`
`specify how much this first body can move with
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`respect to the second body, how much and in what
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`Shorya Awtar, Ph.D. - June 17, 2019
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`ways, in what ways --
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` MR. KATZ: If I can just interrupt you
`
` for a moment, off the record.
`
` (Discussion held off the record.)
`
` MR. KATZ: Back on the record.
`
`BY MR. KATZ:
`
` Q. So I'm sorry for interrupting you were
`
`explaining?
`
` A. All the ways in which one body can move
`
`with respect to another body. In general, there are
`
`six ways in which one body can move with respect to
`
`another body, and there's no coupling, there's no
`
`attachment, there's no connection between the two.
`
`The six ways are three translations and three
`
`rotations. And those six ways in which a certain
`
`body can move with respect to another body are
`
`referred to as the degrees of freedom.
`
` Depending on the nature of the coupling
`
`between these two bodies, if they are completely
`
`de-coupled, if they're completely disconnected, then
`
`the first body has six degrees of freedom, which is
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`what I described, three translations and three
`
`rotations. But if there's some coupling between the
`
`two, then the degrees of freedom would be either five
`
`or four or three or two, depending on the nature of
`
`the coupling between the two bodies.
`
` Q. Is the six degrees of freedom the
`
`maximum between two bodies?
`
` A. Between two bodies, yes. Six degrees of
`
`freedom is between two rigid bodies. It is not
`
`uncommon to refer to -- refer to articulated robotic
`
`arms -- for that matter, even a human arm -- where,
`
`because you're not talking about just two bodies,
`
`you're talking about multiple bodies, when you count
`
`all the relevant degrees of freedom of the multiple
`
`bodies, you can exceed six degrees of freedom.
`
` Q. So I put some premarked documents in
`
`front of you, you've seen, and we're going to go to
`
`IS-1010, which is the Anderson patent.
`
` A. Question: Were these also premarked?
`
` Q. Yes, everything's, yeah, premarked. You
`
`see there are some numbers on the bottom? They don't
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`have the regular deposition stickers, but they've
`
`already been printed with exhibit numbers.
`
` A. Sure. Okay.
`
` Q. And have you looked at the Anderson
`
`patent before?
`
` A. I have.
`
` Q. And just to orient ourselves, do you
`
`understand the Anderson patent as a disclosure of a
`
`surgical robotic system?
`
` A. Yes.
`
` Q. Why don't we first start with column 1
`
`of the patent. Just orienting ourselves, look down
`
`at line 52.
`
` A. Yes.
`
` Q. I just want to read that into the
`
`record. It says, "The laparoscopic surgical
`
`instruments generally include a laparoscope for
`
`viewing the surgical field and working tools defining
`
`end effectors. Typical surgical end effectors
`
`include clamps, graspers, scissors, staplers, and
`
`needle holders, for example."
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`Shorya Awtar, Ph.D. - June 17, 2019
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`Page 28
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` Do you see that?
`
` A. Yes.
`
` Q. And do you understand the term "stapler"
`
`there? I guess, do you have an understanding of what
`
`a stapler is in the laparoscopic context?
`
` A. Yes.
`
` Q. What is your understanding?
`
` A. So a stapler in a laparoscopic context
`
`can mean one of multiple things. It includes an
`
`instrument that's just staples in a laparoscopic
`
`manner. It can include an instrument that staples as
`
`well as cuts a tissue.
`
` Q. Earlier you mentioned a linear stapler.
`
`You understand there's also circular staples as well?
`
` A. Yes.
`
` Q. Are there any other types, or is it
`
`pretty much linear and circular?
`
` A. My understanding is that you have linear
`
`and circular, but you also have staples that look
`
`like more regular staples, or the stapler looks like
`
`more regular staplers, the ones that we use in
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`offices. There might be an open, an incision, and
`
`the staple is fired just sequentially one at a time
`
`to close the surgical opening that might exist.
`
`There may be more also; I wouldn't know.
`
` Q. So you're not familiar with all the
`
`types of surgical staplers?
`
` A. I don't know what I don't know, I guess.
`
` Q. Okay. Then if you turn to column 11, it
`
`starts describing Figure 2. I don't know if it's
`
`possible to have Figure 2 and column 11 --
`
` A. Can I use a second copy of the same
`
`patent?
`
` Q. You can, or you can separate the
`
`document; that's fine, too.
`
` A. I'm at Figure 2 and column 11. Okay.
`
` Q. Just to orient of yourself, you
`
`understand that Figure 2 discloses a surgical
`
`instrument that can be coupled to a robotic system?
`
` A. Yes.
`
` Q. And a surgical -- one kind of
`
`end-effector on the left-hand side which is connected
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`by a shaft -- strike that. Let me start over.
`
` In Figure 2 of Anderson, do you
`
`understand that there's a tool-mounting portion on
`
`the right-hand side which is coupled to a shaft which
`
`is coupled to an end effector?
`
` A. Yes.
`
` Q. Okay. And see the reference to "E"
`
`there?
`
` A. Yes.
`
` Q. And you understand that's conveying the
`
`shaft can roll?
`
` A. Yes.
`
` Q. And that would be one degree of freedom?
`
` A. Yes.
`
` Q. And in the text at column 11 it says --
`
`referring now to Figure 2, "Surgical instrument 28
`
`suitably includes an elongated shaft 28.1, having a
`
`proximal end 33, and a distal end 31, and a pivot 32,
`
`and end effector 38, disposed at the distal end, and
`
`an instrument-based 34 disposed at the proximal end."
`
` Do you see that?
`
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