UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`LKQ CORPORATION and KEYSTONE AUTOMOTIVE INDUSTRIES, INC.,
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` Petitioners,
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` v.
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` GM GLOBAL TECHNOLOGY OPERATIONS, LLC
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` Patent Owner.
`
` IPR 2020-00534
`
` U.S. Design Patent Owner No. D797-625
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` Remotely held videotaped deposition of
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`THOMAS V. PETERS taken before CAROL CONNOLLY, CSR, CRR,
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`and Notary Public, pursuant to the Federal Rules of Civil
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`Procedure for the United States District Courts
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`pertaining to the taking of depositions, at commencing at
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`9:00 a.m. on the 1st day of December, A.D., 2020.
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`Ex. 1044, LKQ v. GM
`IPR2020-00534
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`1
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`
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`LKQ CORPORATION and KEYSTONE AUTOMOTIVE INDUSTRIES, INC.,
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` Petitioners,
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` v.
`
` GM GLOBAL TECHNOLOGY OPERATIONS, LLC
`
` Patent Owner.
`
` IPR 2020-00534
`
` U.S. Design Patent Owner No. D797-625
`
` Remotely held videotaped deposition of
`
`THOMAS V. PETERS taken before CAROL CONNOLLY, CSR, CRR,
`
`and Notary Public, pursuant to the Federal Rules of Civil
`
`Procedure for the United States District Courts
`
`pertaining to the taking of depositions, at commencing at
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`9:00 a.m. on the 1st day of December, A.D., 2020.
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`Ex. 1044, LKQ v. GM
`IPR2020-00534
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`1
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`Page 2
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` There were present at the taking of this
`deposition the following counsel:
` IRWIN IP, LLC by
` MR. BARRY F. IRWIN (via Zoom)
` 222 South Riverside Plaza
` Suite 2350
` Chicago, Illinois 60606
` (312) 667-6081
` birwin@irwinip.com
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` appeared on behalf of the Petitioner;
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` FISH & RICHARDSON, P.C. by
` MR. JOSEPH HERRIGES (via Zoom)
` 3200 RBC Plaza
` 60 South Sixth Street
` Minneapolis, Minnesota 55402
` (612) 335-5070
` herriges@fr.com
`
` appeared on behalf of the Patent Owner.
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`ALSO PRESENT:
` Ms. Angela Caligiuri
` Mr. Justin Bond, Videographer
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` I N D E X
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`REMOTELY HELD VIDEOTAPED DEPOSITION OF THOMAS V. PETERS
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` TAKEN December 1, 2020
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`Page 3
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`EXAMINATION BY PAGE
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`Mr. Irwin 4
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` - - - - - - - -
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` EXHIBITS MARKED
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` PAGE
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`Exhibit 1001 U.S. Patent No. 66
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` D797,625
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`Exhibit 1006 U.S. Patent No. 82
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` D773,340
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`Exhibit 1041 IPR2020-00534-Lian 129
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` Pictures (Collage)
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`Exhibit 1042 IPR2020-00534-Lian 130
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` Pictures (Collage)
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` THE VIDEOGRAPHER: Good morning. Today's date is
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`December 1st, 2020. We are on the record at 9:00 a.m.
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`Today we'll take a videotaped deposition of Thomas
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`Peters. This deposition is being held remotely.
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` Would you please swear the witness.
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` THOMAS PETERS,
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`called as a witness herein, having been first duly sworn,
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`was examined upon oral interrogatories and testified as
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`follows:
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` EXAMINATION
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` By Mr. Irwin:
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` Q Mr. Peters, could you state your full name for
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`the record, please.
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` A Yes. My name is Thomas Van Kirk Peters.
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` Q And, Mr. Peters, again your home address?
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` A It's 1957 Cragin Drive, Bloomfield Hills,
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`Michigan.
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` Q And you and I met. This is the second time
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`that I've deposed you, correct?
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` A That's correct.
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` Q I've deposed you in another proceeding
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`involving the validity of one of GM's patents, correct?
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` A Correct.
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` Q Now I sent you -- like I did last time, I sent
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`you a binder again. Did you get that binder?
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` A Yes.
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` Q Have you opened it, the box?
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` A Yes, yes.
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` Q Okay. Could you please pull the binder out so
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`we can step through what's in there, make sure it's
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`clear.
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` By the way, Joe, Mr. Herriges, I've also made
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`what I sent him available on Exhibit Share, and the
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`binder includes what was populated on Exhibit Share.
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`Okay?
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` MR. HERRIGES: Okay.
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` MR. IRWIN: Q So, Mr. Peters, if you have the
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`binder, just -- there should be a table of contents in
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`the front.
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` A Yes.
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` Q And there's four numbered tabs, 1 through 4,
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`and behind Tab 1 is the patent at issue, the '625 patent,
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`correct?
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` A Okay. Yes.
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` Q And behind Tab 2 is the primary prior art
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`reference, what we will refer to as the Lian reference,
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`correct?
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` A Yes.
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` Q And behind Tab 3 is the -- what we'll refer to
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`as the Tucson reference.
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` A Yes.
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` Q And behind Tab 4 is the declaration that you've
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`submitted in this proceeding, correct?
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` A Yes.
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` Q Now, behind the Tabs A and B are the exhibits
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`that you originally had to your declaration.
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` A Uh-huh.
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` Q Correct?
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` A Yes.
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` Q And then behind Tabs C through Z are prior art
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`references, correct?
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` A Yes.
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` Q All right. And the prior art references that
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`are behind Tab C through Z are the prior art references
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`that you identified in your declaration under the section
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`related to crowded fields?
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` A Yes.
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` Q Would you agree with that portion of your
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`declaration?
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` A Yes.
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` Q Let's take just -- Just to verify that we've
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`got the right exhibits, if you turn to page 25, that's
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`the section of your declaration dealing with the product,
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`so-called the crowded field, correct?
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` A Let me just get to that.
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` MR. HERRIGES: Barry, just a second -- At least on
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`Exhibit Share, as it's currently populated, only has the
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`previous exhibit.
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` MR. IRWIN: Joe, we're having trouble hearing you.
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` MR. HERRIGES: The Exhibit Share only has the
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`previously marked exhibits.
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` MR. IRWIN: Okay. They're coming in now, Joe. I'm
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`sorry. I thought they were already populated. I'm sorry
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`about that, Joe. They should be there, soon.
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` Q Mr. Peters, I'm sorry -- You're looking at
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`page 25, correct?
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` A Yes.
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` Q And we're just verifying that that's a section
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`that you start talking about the crowded fields?
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` A Uh-huh. Yes.
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` Q And then you list a number of patents starting
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`on the page 26 that -- as representative of the crowded
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`field. Do you see that?
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` A Yes.
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` Q Okay. I don't know. You might want to pull
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`out page 26 just temporarily from the binder so that you
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`can easily flip through the patent and start at C and
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`verify that we've attached them in the same order that
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`you have them in paragraph 26 -- on page 26.
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` A Okay.
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` Q Okay. So behind Tab C is the '149 patent? If
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`you could just say something.
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` A Yes.
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` Q Okay. And then behind Tab D is the '607
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`reference, correct?
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` A Tab D?
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` Q Yes, sir.
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` A Behind Tab D I've got '607.
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` Q All right. Behind Tab E, what do you have?
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` A Tab E, it's '753.
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` Q And just as we go through these, verify -- If
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`you see anything inconsistent with the list that you have
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`on page 26, please let me know.
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` A All right. Let's just go through and just to
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`make sure I check all these off then.
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` Q Behind Tab --
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` A Wait. Hold on.
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` Q Let me know when you're ready.
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` A I just want to go back here -- You want to go
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`through each one of us?
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` Q You know what, all I want you to do is verify
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`behind Tab C and Z are the references that you listed on
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`the beginning of page 26 in the order in which you list
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`them.
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` A Okay. Let me go through each one then and just
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`check them off.
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` Q Okay.
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` A Almost done here.
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` Q No worries.
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` A Okay. I've gone through Z here, and they all
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`correlate.
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` Q Okay. Great. Thanks. All right. So we'll
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`come back to those later. Just wanted to go through the
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`binder and make sure that you had what we thought we sent
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`you.
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` So let's start with the definition of designer
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`of ordinary skill in the art. Do you understand that
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`concept, designer of ordinary skill in the art?
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` A Yes.
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` Q And you've formulated a viewpoint with regard
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`to who a designer of ordinary skill in the art is in the
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`context of this dispute, correct?
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` A Yes. Can you specifically -- Which paragraph
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`are you addressing that so I'm clear?
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` Q We'll get to that in a minute. Just wanted to
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`verify that you have formulated a viewpoint as to who a
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`designer of ordinary skill in the art is for the purposes
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`of this proceeding, correct?
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` A That's correct.
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` Q Okay. And do you have an understanding of the
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`significance or what role the designer of ordinary skill
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`in the art plays in the context of this proceeding?
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` A Yes.
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` Q What role does the designer of ordinary skill
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`in the art play in the context of this proceeding?
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` A Well --
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` MR. HERRIGES: Objection.
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` THE WITNESS: It's stated in my declaration.
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` MR. IRWIN: Q I just want to know your
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`understanding.
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` A My understanding is that if you look at
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`paragraph 27 on page 11 --
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` Q Mr. Peters, just so I'm clear, I'm not asking
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`you right now what the definition is. We'll get there.
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` A Okay.
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` Q I know that paragraph you're talking about, it
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`sets forth definitions. All I'm asking you right now is
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`what your understanding is of the role that the designer
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`of ordinary skill in the art plays in the context of this
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`proceeding.
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` MR. HERRIGES: Objection. Vague. Calls for a legal
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`conclusion.
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` THE WITNESS: It again says in the document here --
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` MR. IRWIN: Q Can you answer that question without
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`reviewing the document?
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` A Yes, I can, but I want to make sure I'm very
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`clear and that it's specific.
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` Q Hold on one second. I want to understand your
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`understanding without relying upon the document. Do you
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`understand that, Mr. Peters? Can you answer my question
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`without reliance on the document?
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` A Okay.
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` MR. HERRIGES: Peter, you do not have to do that.
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`You can feel free to reference your report as often as
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`you want.
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` MR. IRWIN: He has to answer my question,
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`Mr. Herriges. Stop instructing him not to.
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` Q Mr. Peters, can you tell me without reference
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`to the document what your understanding of the role a
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`designer of ordinary skill in the art plays in reference
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`to this proceeding?
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` A And I will --
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` MR. HERRIGES: I will tell you, Mr. Peters, you can
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`reference the document that they sent you as often as you
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`want.
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` MR. IRWIN: No. You're instructing him to disregard
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`my question, Mr. Herriges. It's improper.
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` Q Mr. Peters, can you answer my question? If you
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`can't answer it without reference to the document, that's
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`fine, just say that. But I want to know if you can tell
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`me the role the designer of ordinary skill in the art
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`plays in the context of this proceeding without reference
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`to the document.
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` A I guess I need to understand the definition in
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`relation to this proceeding.
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` Q What role does the designer of ordinary skill
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`in the art play in the context of this proceeding without
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`reference to your declaration?
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` MR. HERRIGES: Objection. Vague. Calls for a legal
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`conclusion.
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` THE WITNESS: My role would be to share the
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`designer's perspective of elements of this proceeding.
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` MR. IRWIN: Q Do you understand what the role a
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`designer of ordinary skill in the art plays in the
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`context of this proceeding without looking at the
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`declaration? I see you're looking down.
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` MR. HERRIGES: Objection. He can look at the
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`declaration as much as he wants.
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` MR. IRWIN: No, he can't, Mr. Herriges. My question
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`says without. You're instructing him not to answer my
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`question, Mr. Herriges. Please stop interrupting the
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`deposition.
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` MR. HERRIGES: Tom, again regardless of all the
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`yelling --
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` MR. IRWIN: Mr. Herriges, you are coaching the
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`witness and it's improper. Please stop coaching the
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`witness.
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` MR. HERRIGES: I am not coaching the witness.
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` MR. IRWIN: You are coaching the witness, and we
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`will seek sanctions if you continue.
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` MR. HERRIGES: Okay. That's fine.
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` MR. IRWIN: Q Mr. Peters, please, without
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`reference to the document --
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` A Yes.
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` Q -- can you tell me what you understand the role
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`a designer of ordinary skill in the art plays in the
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`context of this proceeding?
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` MR. HERRIGES: Again, Mr. Peters, you cannot
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`improperly instruct.
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` You can answer the question any way you see
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`fit.
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` MR. IRWIN: No.
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` THE WITNESS: I guess I need more clarification
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`because I want to be absolutely certain what this is
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`addressing. I'm not sure I fully understand the question
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`here. I can tell you as the designer, you know, my role
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`is to show a design perspective as to all the aspects of
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`this proceeding, that's what I was asked to do here.
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` MR. IRWIN: Q Right. But do you understand the
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`significance of the perspective of a designer of ordinary
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`skill in the art to this proceeding?
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` A Relative to my background and experience, yes.
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` Q Anything else in connection with this
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`proceeding that the designer of ordinary skill in the art
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`implicates?
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` MR. HERRIGES: Objection. Vague. Asked and
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`answered.
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` THE WITNESS: My understanding is I'm to provide,
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`you know, my expertise and perspective on all the aspects
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`in this proceeding from a -- the point of view of a
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`designer and relate my experiences and my perception to
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`all of the elements within this document.
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` MR. IRWIN: Q Do you understand what role the
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`perspective of a designer of ordinary skill in the art is
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`supposed to play in the context of this proceeding?
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` MR. HERRIGES: Objection. Asked and answered.
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`Calls --
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` THE WITNESS: As a professional witness. If I
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`understand your question correctly.
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` MR. IRWIN: Q Okay.
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` A For the design perspective.
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` Q Okay. So the designer of ordinary skill in the
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`art is you in this proceeding?
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` A Yes.
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` Q Okay. And you understand that you set forth
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`the qualifications and characterizations of what -- of
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`what you understand is the designer of ordinary skill in
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`the art to be in your declaration?
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` A To the extent of what my understanding of what
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`-- what's expressed in the legal definition. I believe
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`that I meet those parameters.
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` Q When you say legal definition, what do you mean
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`by that?
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` A In reading the description here, the designer
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`of ordinary skill, I'm doing my best to understand what
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`it means from a legal perspective. I know what it means
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`from -- purely what it means from a professional
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`perspective.
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` Q What does it mean from a professional
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`perspective?
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` A It means that I have certain elements of
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`experience professionally and I think also from
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`background as to -- I've had experience with designing
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`aesthetic attributes of products.
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` Q You're referring to yourself?
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` A Yes.
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` Q Okay. But I'm -- I'm asking about the designer
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`of ordinary skill in the art. Do you have an
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`understanding of what qualifications of a designer of
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`ordinary skill in the art in the context of this
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`proceeding?
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` A Okay. I think maybe that helps -- I guess you
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`have to have a design degree, I think you have to have a
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`certain level of professional experience, you know.
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`Experience and a design degree I think those are the two
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`main elements of classifications of an ordinary designer.
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` Q Okay. So a designer of ordinary skill in the
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`art in your art opinion is someone that has a design
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`degree and some level of experience in designing
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`vehicles?
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` A Yes.
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` Q Okay. And so if you use those as sort of the
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`qualifications of a designer of ordinary skill in the
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`art, how has that imaginary person played a role in the
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`opinions that you express in this proceeding?
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` A I think from an ordinary designer you're
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`looking at all of the elements of this proceeding from an
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`aesthetic point of view. I look at all of the elements
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`here we're discussing, you know, from a surface, form,
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`graphic, styling point of view.
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` Q And how does the qualifications of a designer
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`of ordinary skill in the art play a role in that analysis
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`that you did?
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` MR. HERRIGES: Objection. Vague.
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` THE WITNESS: Yeah, I mean, there's different
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`aspects to that. I think -- I'm not sure I fully
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`understand that question, Barry.
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` MR. IRWIN: Q Okay. All right. So let's go back
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`to what you said with regard to designer of ordinary
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`skill in the art as someone that has a design degree and
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`some work experience in vehicle design. With that
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`definition in mind, I want to refer you to paragraph 10
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`of your declaration:
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` A Okay.
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` Q Paragraph 10 of your declaration begins: I
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`believe the good automotive design is a three-dimensional
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`product solution to a problem or challenge that is
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`beautifully executed.
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` Do you see that?
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` A Yes.
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` Q Do you believe a designer of ordinary skill in
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`the art, someone that has a design degree and several
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`years of experience in vehicle design would also believe
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`that?
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` A Yes.
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` Q Next sentence says: The design conveys not
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`only aesthetics but consumer perception of function.
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` Do you believe that a designer of ordinary
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`skill in the art, someone that has a design degree and
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`several years of experience, would also understand the
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`design conveys not only aesthetics, but consumer
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`perception of function?
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` A Yes.
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` Q Would a designer of ordinary skill in the art,
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`someone again that has a design degree and several years
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`of experience in vehicle design, know that when looking
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`at a pre-existing design changes can be made to improve
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`the aesthetics of that design?
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` A Restate that question again, please.
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` Q I'm not going to keep repeating the definition
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`of designer of ordinary skill in the art, but for
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`purposes of these question that means the person that you
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`said has a design degree and work experience in vehicle
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`design.
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` Would a designer of ordinary skill in the art
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`know that when looking at a pre-existing design changes
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`can be made to that design to improve its aesthetics?
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` A That's possible.
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` MR. HERRIGES: Incomplete hypothetical.
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` MR. IRWIN: Q When you say it's possible, is that a
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`yes?
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` MR. HERRIGES: Objection. Asked and answered.
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` THE WITNESS: That's my answer. It's possible.
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` MR. IRWIN: Q What do you mean by it's possible?
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`Is that yes or no?
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` MR. HERRIGES: Same objection.
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` THE WITNESS: Go ahead.
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` MR. IRWIN: Q Or does that mean you don't know?
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` A That means I know, but there's so many
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`variables, it would be based on a specific example.
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` Q So you're saying that --
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` A It may or may not be.
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` Q It may or may not be the case that a designer
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`of ordinary skill in the art would know that you could
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`improve aesthetics to a prior design?
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` MR. HERRIGES: Objection. Incomplete hypothetical.
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`Asked and answered.
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` THE WITNESS: Again, I think it's possible. The
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`possibility exists that you could modify a design or
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`improve it.
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` MR. IRWIN: Q Would that be something that a
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`designer would generally understand, you might be able to
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`improve the aesthetics of design by making modifications?
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` MR. HERRIGES: Objection. Vague. Asked and
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`answered. Incomplete hypothetical.
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` THE WITNESS: To me that means -- depends on what
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`you mean by modifications specifically.
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` MR. IRWIN: Q Changes.
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` MR. HERRIGES: Same objections.
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` THE WITNESS: Again, the possibility exists in
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`Page 20
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`probably most examples.
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` MR. IRWIN: Q Is it also true a designer of
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`ordinary skill in the art would understand that you could
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`make changes to the design to have a different function?
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` MR. HERRIGES: Objection. Incomplete hypothetical.
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` THE WITNESS: Say that again. Ask that question
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`again, please.
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` MR. IRWIN: Q Again, the backdrop of the question
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`is that you say design conveys not only aesthetics but
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`customer perception of function. Okay. The question --
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`With that backdrop the question is would a designer of
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`ordinary skill in the art generally understand that you
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`can change a pre-existing design to convey a different
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`function?
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` MR. HERRIGES: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: That possibility exists.
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` MR. IRWIN: Q That's generally -- that's generally
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`understood that you could possibly change a design to
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`change -- convey a different function?
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` MR. HERRIGES: Objection. Asked and answered.
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` THE WITNESS: Yes.
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` MR. IRWIN: Q Okay. We saw the functions you
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`mentioned are fast, rugged, high quality and class,
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`correct, in terms of design conveying those types of
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`functions?
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` A Yes.
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` Q Okay. What design characteristics would a
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`designer of ordinary skill in the art understand makes
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`something look fast?
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` A Can you ask that question again?
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` Q Again, the backdrop is you're saying the design
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`can convey a certain perception of function, and one of
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`those functions that you suggested is the design could
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`convey is that it looks fast. And so my question is what
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`design characteristics would a designer of ordinary skill
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`in the art understand conveys the function of being fast?
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` A There are many combination of elements that can
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`convey -- convey that thought or convey that image.
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` Q Okay. What I'm looking for is what those are
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`from the standpoint of the designer of ordinary skill in
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`the art. What design characteristics would a designer of
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`ordinary skill in the art understand to convey a function
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`of fast?
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` A From the design perspective, you would utilize
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`proportion, stance, line, and sculpture.
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` Q Okay. What about the proportion would convey
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`the function of fast from the standpoint of a designer of
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`ordinary skill in the art?
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` A I can give you a few examples. I can't show it
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`to you only because there are limitless combinations to
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`convey that. So proportion would be probably low, wide.
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` Q Okay. Again, I'm just looking at things that a
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`designer of ordinary skill in the art would understand
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`convey the function of fast.
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` A Okay. Yes, low and wide.
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` Q Low and wide. Okay. From stance, what aspects
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`of stance would a designer of ordinary skill in the art
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`understand conveys fast?
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` MR. HERRIGES: Objection. Vague.
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` THE WITNESS: Again, I think stance would be the
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`width, the wheel base, and direction I would imagine.
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` MR. IRWIN: Q What do you mean by direction?
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` A That the vehicle would have a taper to it
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`towards the front.
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` Q Got it. All right. What design
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`characteristics regarding the line would a designer of
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`ordinary skill in the art understand makes something look
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`fast?
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` A I think line contributes to visual tension and
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`direction.
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` Q What do you mean by that?
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` A Usually the line, if it's sloping from rearward
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`towards the front, if it has a sloping direction or we
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`call it design references like a rake, an attitude, and
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`then, you know --
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` Q Okay. And you mentioned sculpture. What
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`design aspects of sculpture would a designer of ordinary
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`skill in the art understand conveys a function of fast?
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` MR. HERRIGES: Objection. Vague, incomplete
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`hypothetical.
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` THE WITNESS: That's difficult in that it -- all
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`these systems, all these elements of design work together
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`to create an image. And the sculpture -- there are
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`examples of sculpture that are clear and some that are
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`full, but they can convey fast or luxurious or different
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`characteristics. So that's a difficult one because it's
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`-- it's tough to isolate these elements in what -- what
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`kind of surfacing is fast, that would demonstrate fast.
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`That I can't answer directly.
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` MR. IRWIN: Q Okay. What design characteristics
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`would a designer of ordinary skill in the art understand
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`to convey a function of rugged?
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` MR. HERRIGES: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: There's so many variables in this
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`regard in all what you're asking, Barry. Rugged again is
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`a combination of many different elements, and there are
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`different levels of something being rugged from a design
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`standpoint.
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` MR. IRWIN: Q And what characteristics though
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`would a designer of ordinary skill in the art understand
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`would convey that function of rugged?
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` A Oh, God. Something previously stated,
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`proportion, stance, sculpture and line, working in
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`concert.
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` Q What about the proportion would a designer of
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`the ordinary skill in the art understand to coney a
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`function of rugged?
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` A That also is challenging in that there are
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`different elements of proportion in combination with all
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`-- with some of the -- with some of the expressed
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`elements, that combination convey different levels of
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`vehicle being rugged.
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` Q Can you identify any specific design
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`characteristics that a designer of ordinary skill in the
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`art would understand to convey a function of rugged?
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` MR. HERRIGES: Objection. Vague. Asked and
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`answered.
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` THE WITNESS: As an example, I would say elements of
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`line and form and proportion that have a substantial
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`structure, image of structure and strength.
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` MR. IRWIN: Q Any other examples of character --
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`design characteristics that a designer of ordinary skill
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`in the art would understand to convey a function of
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`rugged?
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` A Again, I think it's a combination of many
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`different elements that include those above it could also
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`be the addition of how the grilles are executed, wheels
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`and tires, visible suspension, those kind of elements.
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` Q What about high level of precision, what design
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`characteristics would a designer of ordinary skill in the
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`art understand to convey a function of a high level of
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`precision?
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` MR. HERRIGES: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: From a design perspective it would be
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`the characteristics of the sculpture, it would be how the
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`panels interface with each other, how the different
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`elements of the design of a vehicle would coordinate and
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`relate to each other relative to finish and materials.
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` MR. IRWIN: Q What about the sculpture -- what
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`sculptural design characteristics would a designer of
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`ordinary skill in the art understand to convey a function
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`of high level of precision?
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` MR. HERRIGES: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: From a design perspective it would be
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`if the sculpture or the surfacing was consistent with and
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`-- with no flaws.
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` MR. IRWIN: Q What do you mean by flaws?
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` A Any waviness or in the reflection lines if the
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`-- they are not consistent.
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` Q Would that -- Wouldn't you want that to be
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`generally true for all vehicle design, that you would
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`want no flaws?
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` A Yes.
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` MR. HERRIGES: Objection.
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` MR. IRWIN: Q Is there anything unique about the
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`sculptural design characteristics that a designer of
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`ordinary skill in the art would understand to convey a
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`function of high level of precision?
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` A Can you ask that question again?
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` Q Is there anything unique in regards to the
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`sculptural design characteristics that a designer of
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`ordinary skill in the art would understand conveys the
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`function of high level precision?
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` MR. HERRIGES: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: Again, I would say consistency of the
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`sculpture and how the panels relate based upon not only
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`the design lines but how the sculptures translate from
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`panel to panel.
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` MR. IRWIN: Q Okay. So let's move then from
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`general vehicle design characteristics to specific design
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`characteristics for fenders. Okay. With regard to a
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`fender, what design characteristics would a designer of
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`ordinary skill in the art understand would make a fender
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`look rugged?
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` MR. HERRIGES: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: There's so many -- there are limitless
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`ways to express that by panel. I will tell you -- I
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`would say that a specific panel, say, a fender -- in
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`order to convey a certain characteristics, and, for
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`instance, what you're saying is rugged would have to
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`relate to the overall vehicle impression. It would have
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`to tie into it usually.
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` MR. IRWIN: Q I understand that. Are there any
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`sort of design characteristics that a designer of
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`ordinary skill in the art would understand could b
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