UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`) CASE IPR2019-00080
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`) US Patent No. 7,850,460
`
`FORMFACTOR, INC.,
` Petitioner,
`VS.
`FEINMETALL, GmbH,
` Patent Owner.
`
`ORAL DEPOSITION OF
`FREDERICK TABER
`JUNE 26, 2019
`VOLUME 1 - JOB NO: 162857
`ORAL DEPOSITION of FREDERICK TABER,
`produced as a witness at the instance of the Patent
`Owner, and duly sworn, was taken in the above-styled
`and -numbered cause on the 26th of June, 2019, from
`9:01 a.m. to 5:47 p.m., before Therese J. Casterline,
`CSR in and for the State of Texas, reported by machine
`shorthand, at the offices of Sheppard, Mullin,
`Richter & Hampton LLP, 2200 Ross Avenue, 24th Floor,
`in the City of Dallas, County of Dallas, State of
`Texas, pursuant to the Federal Rules of Civil
`Procedure and the provisions stated on the record.
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`Feinmetall Exhibit 2008
`FormFactor, Inc. v. Feinmetall, GmbH
`IPR2019-00082
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`) CASE IPR2019-00080
`)
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`))
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`) US Patent No. 7,850,460
`
`FORMFACTOR, INC.,
` Petitioner,
`VS.
`FEINMETALL, GmbH,
` Patent Owner.
`
`ORAL DEPOSITION OF
`FREDERICK TABER
`JUNE 26, 2019
`VOLUME 1 - JOB NO: 162857
`ORAL DEPOSITION of FREDERICK TABER,
`produced as a witness at the instance of the Patent
`Owner, and duly sworn, was taken in the above-styled
`and -numbered cause on the 26th of June, 2019, from
`9:01 a.m. to 5:47 p.m., before Therese J. Casterline,
`CSR in and for the State of Texas, reported by machine
`shorthand, at the offices of Sheppard, Mullin,
`Richter & Hampton LLP, 2200 Ross Avenue, 24th Floor,
`in the City of Dallas, County of Dallas, State of
`Texas, pursuant to the Federal Rules of Civil
`Procedure and the provisions stated on the record.
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`Feinmetall Exhibit 2008
`FormFactor, Inc. v. Feinmetall, GmbH
`IPR2019-00082
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` A P P E A R A N C E S
`
`FOR THE PETITIONER:
` Mr. Jamie McDole, ESQ.
` HAYNES AND BOONE
` 2323 Victory Avenue
` Dallas, TX 75219
`
` Mr. David O'Dell, ESQ.
` HAYNES AND BOONE
` 2505 North Plano Road
` Richardson, TX 75082
`
`FOR THE PATENT OWNER:
` Mr. Timothy Cremen, ESQ.
` Mr. Robert Masters, ESQ.
` SHEPPARD MULLIN RICHTER & HAMPTON
` 2099 Pennsylvania Avenue Northwest
` Washington, DC 20006
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` I N D E X
` PAGE
`Appearances 2
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`WITNESS: FREDERICK TABER
`EXAMINATION BY MR. CREMEN 5
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`Changes and Signature 248
`Reporter's Certificate 250
`
` EXHIBITS
`NUMBER DESCRIPTION PAGE
`Exhibit 2006 United States Patent
` Number 5,977,787 23
`Exhibit 2007 Handwritten drawing 125
`
`(Previously marked)
`Exhibit FF1001 United States Patent
` Number 7,850,460 BS 62
`Exhibit FF1002 Report on the Filing or
` Determination of an Action
` Regarding Patent or Trademark 162
`Exhibit FF1004 Declaration of Frederick
` Taber under 37C.F.R. ? 1.68
` in Support of Petition for
` Inter Partes Review 16
`Exhibit FF1006 Yazaki English interpretation
` of 8-4-00 Patent Application
` Publication Number 2000-214182 181
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` EXHIBITS
`NUMBER DESCRIPTION PAGE
`(Previously marked)
`Exhibit FF1008 United States Patent
` Application Publication
` Number US 2006/0170440 A1 197
`Exhibit FF1010 United States Patent
` Application Publication
` Number US 2005/0110506 A1 232
`Exhibit FF1012 Nguyen Patent
` Application Publication
` Number US2002/0113612 A1 165
`Exhibit FF1014 United States Patent
` Number 3,806,801 75
`Exhibit FF1016 United States Patent
` Number 4,027,935 75
`Exhibit FF2004 United States Patent
` Number 6,515,496 163
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` P R O C E E D I N G S
` THE REPORTER: Counsel, could you
` state your appearances for the record,
` please.
` MR. CREMEN: Timothy Cremen on behalf
` of Patent Owner Feinmetall. And with me is
` Robert Masters, also on behalf of Patent
` Owner Feinmetall.
` MR. McDOLE: Jamie McDole on behalf of
` FormFactor and the witness.
` MR. O'DELL: David O'Dell, also on
` behalf of FormFactor and the witness.
` FREDERICK TABER,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. CREMEN:
` Q. Good morning.
` A. Hi. Good morning.
` Q. Could you introduce yourself for the
` record, please.
` A. Yes. I'm Fred Taber, and I'm an
` expert for -- for FormFactor, and I operate a
` business called Taber Consulting.
` Q. Great. Have you been deposed before?
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` TABER
` A. Yes, I have.
` Q. How many times?
` A. Before you start, I wanted to make you
`aware that I have some hearing difficulties.
` Q. Okay.
` A. So I may ask you to repeat questions
`or speak a little bit louder.
` Q. Sure, anytime. I could speak as loud
`as you want.
` A. Thank you.
` Q. So how many times have you been
`deposed before?
` A. Two times.
` Q. Okay. So this might be old hat for
`you, but just reminders. So your testimony is
`under oath today. You know that?
` A. Yes.
` Q. And during our time together, I'll ask
`you questions and you'll answer them, okay?
` A. Yes.
` Q. And your attorneys might object to a
`particular question, but unless they tell you not
`to answer, please go ahead and answer my
`question, okay?
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` TABER
` A. Yes.
` Q. And then if you don't understand a
`question, please just ask me to clarify it, or if
`you want to expand or if I refer you to a
`paragraph, feel free to look at other paragraphs.
`I don't want to -- I'm not trying to trick you.
`I just want you to let me know if there's a -- if
`there's a problem with my question, okay?
` And I'll probably take breaks maybe
`every 60 or 90 minutes, but if you need a break
`before that, just let me know, okay?
` A. (Nods head.)
` Q. Other than the hearing issue you made
`me aware of, is there anything that would prevent
`you from answering questions completely today?
` A. Nothing that I know of.
` Q. Great. What did you do to prepare for
`this deposition, if anything?
` A. To prepare for the deposition?
` Q. Yes.
` A. I reviewed -- of course, reviewed my
`declaration, and I reviewed the documents
`identified in my -- in my declaration.
` Q. About how much time did you spend
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`doing that?
` A. The preparation part?
` Q. Yes.
` A. I would say it could be close to 40
`hours -- 30 hours, 40 hours. I don't have an
`exact count.
` Q. I understand. An estimate is fine for
`our purposes today.
` And without describing any of the
`conversations you had with counsel, did you also
`meet with counsel to prepare for --
` A. Yes, I did.
` Q. -- the deposition?
` Okay. The counsel that's with you
`today?
` A. Yes.
` Q. Anyone else?
` A. There was one other attorney.
` Q. Who was that?
` A. Kelly Lyle.
` Q. Okay. Did you review any documents
`other than your exhibit -- or other than your
`declaration and the exhibits thereto?
` A. No. Of course, I -- including the
`
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` TABER
`'460 patent, I also reviewed that.
` Q. Sure.
` A. Which, of course, I identified in my
`declaration.
` Q. Sure.
` Did you -- have you ever reviewed
`the actual petitions that were filed by
`FormFactor that were based on your declaration?
` MR. McDOLE: Objection, form.
` A. I don't recall reviewing them.
` Q. Did you review Feinmetall's
`preliminary response to FormFactor's petitions in
`this matter?
` A. I don't recall reviewing that.
` Q. Are you aware that there was an expert
`declaration of Dr. Lall attached -- or filed with
`Feinmetall's preliminary responses?
` A. I'm aware of his declaration.
` Q. Have you reviewed that declaration?
` A. I've read his -- read his declaration.
` Q. Okay. And are you aware that the
`Patent Trial and Appeal Board issued notices of
`institution starting these IPRs?
` A. I -- I've read the decisions.
`
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` Q. You've read the notices of
`institution? Okay.
` Okay. Let's look at your declaration.
`Start at the beginning, which is a good place to
`start.
` A. I'm going to be switching glasses back
`and forth.
` Q. That's okay.
` So if we look at -- I guess we'll just
`start at paragraph 1, maybe just a general
`question about the declaration first.
` Who -- how did you prepare it? Just
`walk me through the steps, generally.
` A. The preparation of the declaration?
` Q. Yes.
` A. I worked with -- I worked with the
`attorneys to identify some prior art. I did some
`research on some prior art. I went through each
`one of the -- there's more preliminary stuff that
`was -- that was written; of course, my
`background, my CV, and so forth.
` And then I worked with the attorneys
`on -- on the -- on each of the -- each of the
`claims and the prior art with respect to each --
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` TABER
`each of the claims.
` Q. Who -- how did the writing process --
`how was the writing process done?
` A. It was more or less collaborative.
`I'd say more or less collaborative. There would
`be some ideas from the attorney, there would be
`my ideas, and it was assembled collaboratively.
` Q. Who did the majority of the writing,
`if you --
` MR. McDOLE: Objection, form.
` Q. -- if you -- if you can tell?
` A. I never made a determination as to who
`did the -- who did most of the writing.
` Q. If you had to put a --
` A. I don't know -- I don't know how many
`hours the attorneys spent on it privately, so
`it's hard for me to say, you know, what the split
`was.
` Q. If you had to estimate a percentage
`that you did versus the attorneys did, what would
`you say?
` MR. McDOLE: Objection, form.
` A. I -- I would have to look. I would
`have to look back at it. I can't -- I can't give
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` TABER
`you an answer off the top of my head.
` Q. How many hours did you spend preparing
`the declaration, roughly?
` A. I don't have a tally with me, but I
`would estimate it between 80 and 100, something
`along those lines. It could be more; it could be
`less. I -- I don't have an exact tally.
` Q. All right. Let's look at paragraph 2.
` Is everything in this paragraph 2
`still true?
` A. Everything in there is true.
` Q. Let's look at paragraph 3.
` Oh, I'm sorry, before I go to
`paragraph 3, what is your hourly rate?
` A. 500 per hour.
` Q. Now we can go to paragraph 3. Sorry.
` A. Excuse me?
` Q. Now we can go to paragraph 3.
` And paragraph 3 lists a number of
`exhibits; is that right?
` A. Yes.
` Q. How -- how was this list prepared?
`How did you come in possession of these
`documents?
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` A. I don't -- I don't quite understand
`your question. You mean -- what do you mean?
` Q. Okay. So there's a list of documents
`in paragraph 3, right?
` A. Uh-huh.
` Q. Who first identified each of those
`documents?
` A. Some of these were identified by the
`attorneys, and some of these documents were
`identified by me.
` Q. Can you tell me which ones were
`identified by you?
` A. Two that I'm definite of would be the
`Bove and Byrnes patents. The others, I'm -- I
`don't recall where -- you know, who -- who
`identified it first.
` Q. And for Bove and Byrnes, were you
`aware of those references through your work at
`IBM?
` A. They're both IBM patents, and I've
`worked at IBM, so I've been aware of these
`patents for some time.
` Q. In the second bullet point of
`paragraph 3, you mention the prosecution history
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`of the '460 patent, correct?
` A. Yes.
` Q. When you say the prosecution history,
`do you mean the -- the -- just the back-and-forth
`with the Patent Office and the applicant, or do
`you also mean the references that were part of
`the file history as well?
` A. When I say the prosecution history,
`primarily I mean the back-and-forth with the --
`with the Patent Office.
` There may have been a patent or two
`that I may have looked at that were referred in
`there, but I'm -- I probably refer -- I probably
`looked at all of the patents. As I think
`through, I probably looked through all of the
`patents.
` Q. Look at paragraph --
` A. Certainly in the -- in the '460
`patent, there are a lot of references there.
` Q. Yes.
` A. I may have -- I may have quickly
`looked at each of one of those references, and I
`can't say that I studied each one of the
`references that are part of the '460 patent.
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` Q. Okay. And when you say part of the
`'460 patent, you mean the references that are
`listed on the face of --
` A. On the front -- the front page.
` Q. Okay.
` A. On the face, face page.
` Q. Okay. If we look at paragraph 4,
`there are three additional exhibits listed there
`in bullet point; is that correct?
` A. Yes, there are.
` Q. Why are these listed separately in
`paragraph 4 as opposed to paragraph 3?
` A. Each one of those provides some
`additional corroborating obviousness. They
`weren't used as extensively as all of the other
`patents for obviousness, so just kind of a
`little -- little bit of a separation there. It's
`not that they weren't used; they just weren't as
`heavily relied upon.
` Q. Understood.
` Okay. On -- in paragraph 5, you
`discuss your CV; is that correct?
` A. Yes.
` Q. All right. And that's attached at
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`the -- as an appendix to the end of the
`declaration; is that right?
` A. And I don't have that.
` Q. The last three pages?
` A. I don't have that in my copy.
` Q. All right.
` A. Thank you.
` Q. So I've handed you copies of the last
`three pages of your Exhibit FF1004, starting at
`page 221.
` Is that copy of your CV still accurate
`and current?
` A. It's accurate up to the time that I
`submitted it. Of course, I would, at some point
`in time, include this -- this work here, which is
`not included in there.
` Q. Does your CV on the final page, 223,
`list all the times, other than this matter,
`you've served as an expert witness?
` A. Those are the four times I've served
`as an expert witness.
` Q. So no -- you have not served as an
`expert other than those four times, right?
` A. That's -- that's it.
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` Q. Okay. If we just can walk through
`each of the four matters, and without going into
`any confidential information, could you just give
`me a general understanding -- a general idea of
`what the -- what your role is -- role was.
` A. In the -- in the first one -- would it
`be helpful if I identify the first one for the
`transcript or --
` Q. Sure.
` A. Okay. That's the -- the first one is
`the United States International Trade Commission;
`In the Matter of: Certain Probe Card Assemblies,
`Components Thereof, and Certain Tested DRAM and
`NAND Flash Memory Devices and Products Containing
`the Same.
` I was engaged by the attorneys at
`Phicom. Both Phicom and Micronics were the
`defendants against FormFactor.
` In that case, I prepared --
`I prepared -- I worked on the litigation part and
`prepared an expert report and also testified
`in -- in court.
` Q. What was the -- what was the technical
`subject matter of the case?
`
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` A. The technical subject matter were
`wafer probes.
` Q. And did you testify on patent
`validity --
` A. On?
` Q. On patent validity?
` A. Yes.
` Q. What about infringement?
` A. What about?
` Q. Infringement.
` A. And infringement as well. This is
`going back a few years, so I'm a little fuzzy
`with some of the details.
` Q. Understood. I just want broad
`concepts for these.
` A. Sure.
` Q. Just so I understand.
` A. In the second one, United States
`District Court, District of Arizona; Integrated
`Technology Corporation and Nevada Integrated
`Technology Corporations versus Rudolph
`Technologies.
` In that case, I replaced their
`original expert, and reviewed and modified his
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`expert report as necessary, and I also testified
`at trial.
` That particular case was related to
`wafer probe metrology tools, tools that measure
`performance of the probes offline.
` Q. And was that a patent case as well?
` A. That was a patent case as well.
` Q. And did you testify on patent validity
`in that case?
` A. Yes.
` Q. And infringement?
` A. And infringement.
` The third one, United States District
`Court, Northern District of California;
`Interconnect Devices, Incorporated, versus
`Johnstech International.
` That never went to court. I assisted
`in prior art research prior to the case being
`settled. That case was -- involved a socketing
`technology, which is kind of a sister technology
`to wafer probes.
` Q. In that --
` A. Excuse me?
` Q. Sorry. I lost my train of thought.
`
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` And your role in that was to study
`patent validity as well?
` A. That -- that part in the -- in the
`case, we were -- we were working on identifying
`prior art.
` The fourth one, United States District
`Court, Northern District of California, Oakland
`Division; FormFactor versus Microprobe.
` I was engaged by Microprobe. And,
`again, that was some prior art research before
`the case was settled. We did not produce an
`expert report or any testimony or any deposition.
` Q. And that research was related to
`patent validity, right?
` A. Yes. And, again, that was a wafer
`probe-related case.
` Q. So in these four roles, were you only
`deposed in the ITC case and the District Court of
`Arizona case?
` A. Yes. Those are the only two that I
`was deposed.
` Q. And which -- were those -- sorry. Let
`me start over.
` And those two cases you produced
`
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`expert reports or declarations?
` A. In the first one, I produced an expert
`report. In the second one, there was a prior
`expert who produced an expert report, and then I
`reviewed that and made some relative changes to
`it.
` Q. Okay. Let's go back to your
`declaration.
` A. If I can go back to that second one.
` Q. Sure.
` A. I don't recall the -- the extent of
`any modifications that I did. I would have to
`look back at that.
` It may have been, you know, just some
`tiny wording or not, and I may have just accepted
`that report as well.
` Again, I'd have to go back and look at
`my notes to understand exactly what -- what
`happened there.
` Q. Okay.
` A. It was not a major rewrite.
` Q. Okay. Let's look at paragraph 6 of
`your declaration.
` A. Yes.
`
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` Q. You indicated your -- your
`professional career was -- is over 48 years and
`that 26 have been focused on wafer probes and
`socketing, correct?
` A. That's correct.
` Q. So what was the other 22 years? What
`was the --
` A. If you look at paragraph 10.
` Q. Okay.
` A. Paragraph 10 describes my early work.
`In summary, it was work related to test systems
`for the manufacturing floor. So I
`designed/developed/installed test systems for --
`for testing of various -- various products at
`different levels of assembly, including wafers.
` Q. And then after that is when you
`started to focus on probes --
` A. Right.
` Q. -- is that fair to say?
` A. Fair to say. The -- the first part of
`my career was spent at one IBM location, and then
`the -- the second part, starting in 1989, was in
`another location.
` Q. What was the second location?
`
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` A. East -- East Fishkill, New York. A
`lot of Dutch people where I live in New York.
` Q. If we look at paragraph 12 of your
`declaration, please.
` A. Sure.
` Q. You mention here that you hold two US
`patents concerning wafer probing technology; is
`that correct?
` A. That's correct.
` MR. CREMEN: I'm going to mark this as
` 2006.
` (Exhibit Number 2006 marked.)
` MR. McDOLE: I'm going to object to
` this exhibit as not previously being
` disclosed to us, under the Rules under IPRs,
` 10 days before the deposition.
` And we'll see what questions you have,
` but I may instruct the witness not to answer
` the questions.
` MR. CREMEN: I believe the rules say
` you can serve at the deposition.
` MR. McDOLE: Actually, it doesn't. It
` says 10 days before. You have to give us
` notice.
`
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` Q. Is this one of the patents you refer
`to in your declaration?
` THE WITNESS: Am I allowed to answer
` this question?
` MR. McDOLE: You can answer that
` question.
` A. Yes, this is one of the patents.
` Q. You can just set it aside. I might
`have a couple of questions on it later, but I
`just want --
` A. Excuse -- excuse me?
` Q. You can just set it aside for now. I
`might have a couple of questions on it later.
` A. Okay.
` Q. I just wanted to confirm that was one
`of the patents you were referring to.
` Okay. Let's look at paragraph 15 of
`your declaration.
` A. Yes.
` Q. So it says you retired from full-time
`work in May 2004, correct?
` A. Excuse me? I apologize.
` Q. It's okay. It's okay. It's okay.
`Just keep reminding me. I'll -- I'll keep trying
`
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`to speak up.
` A. The interesting thing is that
`conference rooms are very difficult because of
`the way the sound bounces around.
` Q. Yeah.
` A. That's where I'm having more
`difficulty. You have a good voice, but --
` Q. Well, thank you.
` So it says you retired from full-time
`work in May 2004, correct?
` A. Yes, I did.
` Q. Okay. And feel free to look at the
`'460 patent to confirm, but that wasn't filed
`until 2009, correct?
` A. That's correct. I don't have that
`patent, but I understand it was filed 2008 or
`2009.
` Q. Okay. In your -- in the, I guess,
`third sentence of paragraph 15, it says you --
`you kept up to date on developments in the field
`of wafer probing due to your work as a test
`technology consultant, correct?
` A. That's what I said, yeah.
` Q. So without divulging any confidential
`
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`information that -- involving your work as a
`consultant, just give me some examples of
`projects that you worked on that would have kept
`you up to date.
` A. One that comes to mind is a probe
`technology that was experiencing some unusual
`wear-out problems, so I took on that project to
`identify the failure mechanisms and prescribe
`a -- a solution for those -- that particular
`problem.
` Q. Okay. And -- and as part of the
`prescribing a solution, did you review other
`technologies?
` Let me ask the question a different
`way.
` As part of prescribing the solution,
`what did you do?
` A. Since the -- the technology that I was
`evaluating used a different kind of metallurgy, I
`needed to understand the performance of other
`probe technologies with different metallurgies,
`and that led me to some -- some approach, some
`experiments and so forth, that helped me identify
`where the issues were and the problems.
`
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` Q. Do any other projects come to mind?
` A. I worked on another project where a
`particular company was interested in introducing
`a buckling beam probe technology, and I assisted
`them in some of the early development work for
`that buckling beam technology.
` Q. Any -- anything else?
` A. Those are the two primary ones that
`come to mind.
` Q. And what -- what is --
` A. I don't have the list of all of my
`projects with me, so --
` Q. Understood.
` What were the time frames of those
`projects, roughly?
` A. Oh, I'd -- I'd rather not speculate
`what the time frame was. It certainly was after
`2004 when I retired, and I'm trying to put a cap
`on the other end.
` You know, I -- I don't know
`specifically. I don't recall specifically what
`the -- what the dates were.
` Q. As you sit here, do you think it was
`before 2008?
`
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` A. I think at least one of them was
`before 2008.
` Q. Is there a --
` A. I would -- I really would need to
`review my -- that material. That's not something
`that I've looked at, though, recently.
` Q. Sure. Sure. I was just trying to get
`a handle on work you did to keep you up to date.
` A. Sure, sure.
` Q. So is there -- was there any other
`work that would have kept you -- let me start
`over.
` Is there any other work that you
`performed as the -- as a consultant between 2004
`and 2008 that would have kept you up to date on
`developments in probe design?
` A. Well, I have some very close
`associations in the industry, so I -- I was a
`member of the committee of the Semiconductor
`Wafer Test Workshop, where papers on wafer --
`wafer probing are presented. I chaired a number
`of sessions there over the years.
` I was the proceedings coordinator,
`which meant that I got to review each one of
`
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`the -- each one of the papers.
` In that period of time, I was also the
`founder and general chairman of the BiTS
`Workshop, which is on the socketing end.
` Socketing technology and probe
`technology face similar challenges, even though
`they're related to different levels of assembly
`of semiconductors, so the assembler technological
`issues between those two technologies, and it's
`called a BiTS Workshop, and so I ran that for 15
`years.
` Q. And the answer to this might be BiTS
`Workshop, but is there a particular organization
`or -- or publication that -- that you would say
`is a -- provides a -- is a good source of product
`development news in the probe design realm?
` A. Well, the -- the primary forum is the
`Semiconductor Wafer Test Workshop, and that's --
`that's where probe technologists from around the
`world gather once a year.
` In terms of publications, there's a
`couple of publications that I subscribe to. I
`can't say that they talk about wafer probing all
`the time, but there's an IEEE publication called
`
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`Design & Test and another publication called
`Computer.
` Q. Is the latter publication an IEEE?
` A. They're both IEEE.
` Q. Were both the IEEE publications and
`the SWTW organization around in 2008?
` A. Were all those --
` Q. Yes.
` A. I'm sorry. Were all of those around
`in 2008?
` Q. Yes, yes.
` A. Oh, yeah, definitely.
` Q. When did those -- you can -- let me
`start over. And you can answer for each three --
`all three of them separately.
` When did each of them --
` A. Well, I've been -- I've been a member
`of the IEEE since around 1999 or so. And at that
`point in time, when you engage in a -- becoming a
`member, you have the opportunity to subscribe to
`different publications. And, you know, so I
`subscribed to those two publications beginning at
`that time frame, and I'm still -- I'm still a
`member and still receiving those.
`
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` As far as the Semiconductor Wafer Test
`Workshop, I first attended in 1994 and have
`attended for 25 years.
` Unfortunately, my schedule didn't
`permit me to attend the last couple of years, but
`I attended pretty much consecutively since 1994;
`may have missed one, but pretty much
`consecutively.
` Q. And besides those three, are there any
`other sources of probe design information or news
`that a person of ordinary skill in the art would
`have referenced in 2008 or before?
` A. It was a good friend of mine who
`founded the Semiconductor Wafer Test Workshop,
`was instrumental in pulling together a tutorial
`about the leading edge of wafer probe technology
`and some -- some WaferTech probe technology
`basics, so that tutorial was available. He
`provided me with that -- with his -- his
`information, though I did not attend his
`tutorial.
` Q. Who is that?
` A. He's now deceased. His name is
`William Mann
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