UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`-----------------------------x
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`APPLE, INC.,
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` Petitioner,
`
` vs.
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`COREPHOTONICS, LTD.,
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` Patent Owner.
`
`Case No. IPR2020-00897
`U.S. Patent No. 10,324,277
`
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`Case No. IPR2020-00878
`U.S. Patent No. 10,330,897
`
`-----------------------------x
`
` Videotaped Deposition of TOM MILSTER
`
` Monday, April 12, 2021
`
`Reported by:
`
`Christina Diaz, CRC, CRR, RMR, CSR
`
`Job No.: 1931
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`APPL-1028 / Page 1 of 222
`APPLE INC v. COREPHOTONICS LTD.
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`-----------------------------x
`
`APPLE, INC.,
`
` Petitioner,
`
` vs.
`
`COREPHOTONICS, LTD.,
`
` Patent Owner.
`
`Case No. IPR2020-00897
`U.S. Patent No. 10,324,277
`
`Case No. IPR2020-00896
`U.S. Patent No. 10,317,647
`
`Case No. IPR2020-00878
`U.S. Patent No. 10,330,897
`
`-----------------------------x
`
` Videotaped Deposition of TOM MILSTER
`
` Monday, April 12, 2021
`
`Reported by:
`
`Christina Diaz, CRC, CRR, RMR, CSR
`
`Job No.: 1931
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPL-1028 / Page 1 of 222
`APPLE INC v. COREPHOTONICS LTD.
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`Page 2
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` April 12, 2021
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` 8:58 A.M. P.D.T.
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` Videotaped deposition of TOM
`
`MILSTER, conducted remotely, before Christina
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`Diaz, a Certified Realtime Captioner,
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`Certified Realtime and Registered Merit
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`Reporter and Notary Public within and for the
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`State of New York.
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`APPL-1028 / Page 2 of 222
`APPLE INC v. COREPHOTONICS LTD.
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`Page 3
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` A P P E A R A N C E S
`
` HAYNES and BOONE, LLP
`
` Attorneys for Petitioner
`
` 2323 Victory Avenue, Suite 700
`
` Dallas, TX 75219
`
` 214.651.5078
`
` BY: STEPHANIE SIVINSKI, ESQ.
` stephanie.sivinski@haynesboone.com
`
` MICHAEL S. PARSONS, ESQ.
` michael.parsons@haynesboone.com
`
` JORDAN M. MAUCOTEL, ESQ.
` jordan.maucotel@haynesboone.com
`
` RUSS AUGUST & KABAT
`
` Attorneys for Patent Owner
`
` 12424 Wilshire Boulevard
`
` Los Angeles, CA 90025
`
` 310.826.7474
`
` BY: JONATHAN LINK, ESQ.
` jlink@raklaw.com
`
` ALSO PRESENT:
`
` JOSE SASIAN
`
` PRIYA VISWANATH, Cooley LLP
`
` BETSY GOMEZ, Videographer
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`APPL-1028 / Page 3 of 222
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`Page 4
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` I N D E X
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`WITNESS
`
`Tom Milster
`
`EXAMINATION BY PAGE
`
`Ms. Sivinski 6
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` E X H I B I T S
` (Exhibits attached to transcript)
`
`MILSTER DESCRIPTION PAGE
`
`Exhibit 1 United States Patent 144
` Number 4,792,316,
` 10 pages
`
`Exhibit 2 United States Patent 148
` Number 4,659,190,
` 13 pages
`
` INFORMATION REQUESTS
`
`INSERTED INFORMATION - NONE -
`
`REQUESTS FOR PRODUCTION - NONE -
`
`RULING - NONE -
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`DIRECTIONS NOT TO ANSWER - NONE -
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`APPL-1028 / Page 4 of 222
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` T. Milster
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` THE VIDEOGRAPHER: We are on the
`
` record on April 12th, 2021 at
`
` approximately 8:58 a.m. Pacific Time for
`
` the remote video deposition of Dr. Tom D.
`
` Milster in the matter of Apple,
`
` Incorporated versus Corephotonics, Ltd.
`
` My name is Betsy Gomez, and I am the
`
` videographer on behalf of TransPerfect
`
` Legal Solutions.
`
` Will counsel please introduce
`
` themselves and the party they represent,
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` beginning with the party noticing this
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` proceeding.
`
` MS. SIVINSKI: Good morning.
`
` Stephanie Sivinski with Haynes and Boone.
`
` I'm here on behalf of petitioner Apple.
`
` I'm joined today by my colleagues, Mike
`
` Parsons and Jordan Maucotel, also of
`
` Haynes & Boone. I'm also joined by
`
` Apple's expert in these proceedings, Jose
`
` Sasian, and our colleague, Priya
`
` Viswanath, from Cooley.
`
` MR. LINK: Good morning. My name is
`
` Jonathan Link from the law firm of Russ
`
`TransPerfect Legal Solutions
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`APPL-1028 / Page 5 of 222
`APPLE INC v. COREPHOTONICS LTD.
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`Page 6
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` T. Milster
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` August & Kabat on behalf of the patent
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` owner Corephotonics.
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` T O M M I L S T E R,
`
` having been remotely sworn as
`
` stipulated by the parties, was examined
`
` and testified as follows:
`
` MS. SIVINSKI: Before we get
`
` started, is the real-time hooked up? If
`
` so, we might go off the record for one
`
` minute so I can set up. Okay. Sorry.
`
` Can we go off the record for one minute?
`
` THE VIDEOGRAPHER: The time is 8:59
`
` a.m., and we're going off the record.
`
` (Recess)
`
` THE VIDEOGRAPHER: The time is 9:01
`
` a.m., and we are going on the record.
`
` EXAMINATION
`
`BY MS. SIVINSKI:
`
` Q. Right. Good morning, Dr. Milster.
`
`Thanks for your patience this morning.
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`212-400-8845 - Depo@TransPerfect.com
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`APPL-1028 / Page 6 of 222
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`Page 7
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` A. Good morning.
`
` Q. So as I indicated earlier, my name
`
`is Stephanie Sivinski, and I'm representing
`
`Apple. I'm going to be taking your deposition
`
`this morning. It's good to meet you.
`
` A. Thank you. Good to meet you.
`
` Q. Have you given testimony in a remote
`
`deposition before?
`
` A. Yes.
`
` Q. So are you familiar with Zoom
`
`controls and downloading exhibits through the
`
`chat function?
`
` A. You know, I'm sorry, I'm a little
`
`hard of hearing, but I think you -- the
`
`question that you asked was have I given a
`
`deposition before, and the answer is yes.
`
`I've never given a Zoom video deposition
`
`before, however.
`
` Q. Okay.
`
` A. I am very familiar with Zoom. We
`
`use it all the time. So I believe that I can
`
`handle anything that's requested of me there.
`
` Q. Okay. Can you hear me better now?
`
`I want to make sure you can hear me. You're
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`APPL-1028 / Page 7 of 222
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`the star of the show today. You need to be
`
`able to hear my questions.
`
` A. Yes, I understand.
`
` Q. Okay.
`
` A. And I'll ask you for clarification
`
`if I don't understand.
`
` Q. Okay. That's helpful. Thank you.
`
` Where are you testifying from today,
`
`Dr. Milster?
`
` A. This is my dining room of my home in
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`Tucson, Arizona.
`
` Q. Okay. Is there anyone else in the
`
`room with you today?
`
` A. No.
`
` Q. Okay. And do you have any access to
`
`notes from where you're testifying today?
`
` A. I have my computer, which has a lot
`
`of information on it. And I also have written
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`-- printed my notes from -- they're not really
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`notes. They're my declaration for each of the
`
`IPRs, the patents printed out and the --
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`Professor Sassian's declarations.
`
` Q. Anything other than the documents
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`you mentioned in the binder that you just held
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`APPL-1028 / Page 8 of 222
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`up?
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` A. No. Well, I do have one page of
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`corrections.
`
` Q. Okay. Well, we can talk about those
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`in a second.
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` Is there any reason that you can't
`
`give truthful and accurate testimony today?
`
` A. No.
`
` Q. So I know you've been deposed
`
`before, but just so we're on the same page,
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`some ground rules.
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` Can you agree to answer pending
`
`questions before we take a break in a
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`particular time?
`
` A. Sure.
`
` Q. Okay. And let me rephrase that
`
`question. I'm happy to take breaks whenever
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`you need them, but I would ask that you answer
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`the question that's pending at the time.
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` Is that acceptable?
`
` A. Yes. Sure.
`
` Q. Okay. And we already talked about
`
`this a little bit, but if you don't understand
`
`one of my questions, will you please let me
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`APPL-1028 / Page 9 of 222
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`know.
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` A. Yes.
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` Q. All right. So do you understand
`
`that you're testifying today about
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`declarations that you submitted in three IPRs?
`
` A. Yes.
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` Q. Okay. Those are IPRs No. 2020-878,
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`2020-896 and 2020-897?
`
` A. Yes.
`
` Q. And I've loaded your declarations in
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`the chat, but it sounds like you also have
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`copies of them with you today, right?
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` A. Correct.
`
` Q. Okay. And you mentioned that you've
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`got a list of corrections. Tell me about
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`those.
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` A. Okay. In the declaration for the
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`878 IPR, paragraph 114 of my declaration.
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` Q. Okay. I'm there.
`
` A. I'm not.
`
` Q. Okay.
`
` A. Yes. So the semidiameter of the
`
`aperture stop is incorrectly listed as .9751.
`
`It should be .9761. And that carries down to
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`APPL-1028 / Page 10 of 222
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` T. Milster
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`a difference in the next sentence that should
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`be 0.0414 millimeters, not .0424 millimeters.
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` Q. Anything else?
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` A. Yes. Paragraph 132. The
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`semidiameter listed there should read
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`1.170486. It doesn't change the calculation
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`of the image side diameter of approximately
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`2.34 millimeters, but that is a correction
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`that I want to note.
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` Q. Okay.
`
` A. And then in the '897 IPR, paragraph
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`115 of my declaration, it's listed that the
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`first modified Example 5 edge thickness from
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`Professor Sassian's declaration -- it's listed
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`in my report as 0.06444 millimeters. It
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`should be 0.060455 millimeters. And then when
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`that correct value is used, the edge thickness
`
`to center thickness ratio should be 18.6.
`
` Q. Okay. So when your declaration says
`
`17.42, that number should be 18.6, right?
`
` A. Yes, ma'am.
`
` Q. Okay.
`
` A. And that's it.
`
` Q. All right. Thank you.
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` All right. So have you read U.S.
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`Patent Number 10,330,897?
`
` A. Yes.
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` Q. And is it okay if I call that the
`
`'897 patent today?
`
` A. Yes.
`
` Q. And then have you read U.S. Patent
`
`Number 10,317,647?
`
` A. Yes.
`
` Q. Is it okay if I call that one the
`
`'647 patent?
`
` A. Yes.
`
` Q. And then last but not least, have
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`you read U.S. Patent Number 10,324,277?
`
` A. Yes.
`
` Q. And is it okay if we call that one
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`the '277 patent today?
`
` A. Yes.
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` Q. Would you agree with me that the
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`'897, '647 and '277 patents share a
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`specification?
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` A. I didn't compare if every word in
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`the specifications was the same or not.
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` Q. So let's see. Okay. That's fine.
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` So let's start with the declaration
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`you issued with respect to the '897 patent
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`today. And I'm going to call that one the
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`'897 declaration. Is that okay with you?
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` A. Yes.
`
` Q. Okay. I know that's a little
`
`confusing because we also have an IPR number
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`that ends with 897, but I will try to refer to
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`the patent numbers. I think that's a little
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`easier.
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` A. Thank you.
`
` Q. So if we look at pages 1, 2 and 3 in
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`that declaration, do you see a bullet pointed
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`list?
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` A. Yes.
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` Q. And are those documents that you
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`considered in rendering your opinions?
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` A. Yes.
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` Q. Did you read all of those references
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`in preparing your declarations?
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` A. There are some that I perused and
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`didn't read completely, but I looked at every
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`item here.
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` Q. And if you will flip with me to page
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`73 of your declaration on the '897 patent,
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`there's a section called "Appendix."
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` Do you see that?
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` A. Yes.
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` Q. And what's included in that
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`appendix?
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` A. Well, I've got several items listed
`
`in that appendix. And there are letters
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`indicating different sections. A, B -- A and
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`B on this one. And the first one -- the first
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`section is entitled "Ogino Example 5 modified
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`for f-number 2.8." And the second one is
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`"Modified Chen Example 1."
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` Q. So I see some figures included in
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`your appendix. Are those figures that you
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`generated?
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` A. (Witness reviewing document).
`
` Yes, I believe so.
`
` Q. And paragraph 153 of your
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`declarations, the beginning of the appendix
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`says that this appendix describes analysis
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`that you performed using Zemax and other
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`software tools.
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` Do you see that?
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` A. Yes.
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` Q. Other than Zemax, what other
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`software fools tools did you use to generate
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`the analysis of this appendix?
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` A. I used MATLAB program.
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` Q. Which parts of the analysis in this
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`appendix did you use MATLAB for?
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` A. For the MATLAB software?
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` Q. Yes. Which part of the appendix did
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`you use MATLAB -- or MATLAB for?
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` A. So in paragraph 157, there's a plot
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`of the sag and the slope versus the radial
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`coordinates, and also a detail of that same
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`figure in that same paragraph.
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` Q. How often do you use Zemax in your
`
`work?
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` A. Just a second. How often do I use
`
`MATLAB in my work?
`
` Q. Zemax.
`
` A. Oh, Zemax. In my research work, I
`
`use that quite a bit.
`
` Q. And do you use it when you're
`
`designing lenses in your day-to-day work?
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` A. I use Zemax quite a lot in my
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`day-to-day work.
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` Q. What do you use it for?
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` A. Mainly designing lenses.
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` Q. So other than the appendix that we
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`just talked about for the '897 declaration,
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`did you use Zemax for the '277 or '647
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`declarations?
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` A. Yes.
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` Q. What analysis did you perform with
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`Zemax for the '277 declaration?
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` A. The '277?
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` Q. Yes, sir.
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` A. (Witness reviewing document).
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` You can see on paragraph 115 that
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`there's an edge thickness calculation.
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` Q. Okay. So you used Zemax to generate
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`that edge thickness calculation?
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` A. Yes.
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` Q. Anything else that you used Zemax
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`for in your '277 declaration?
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` A. I'm reviewing the rest of it now if
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`you'd just give me a moment.
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` Q. Absolutely. Take as much time as
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`you need.
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` A. (Witness reviewing document).
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` That's all I see from my quick
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`glance. There might be others referred to in
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`there, but that's all I could find.
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` Q. Okay. And then what about your
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`declaration related to the '647 patent, did
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`you use Zemax for any of the analysis
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`contained in that declaration?
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` A. (Witness reviewing document).
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` In paragraph 90, there's a figure.
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`And I'm pretty sure that the Ogino Chen
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`Example 5 was just reproduced from Sasian's
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`declaration. I'm not sure if I used Zemax to
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`plot out the left side of that figure or not.
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`I would have to go back and check.
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` Q. Okay.
`
` A. And then on paragraph 91, there is a
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`figure that says "Modified Ogino Example 5,"
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`and then the relative illumination plot, a
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`field curvature and distortion plot and an
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`aberration plot and then a prescription data
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`table.
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` Q. And so those figures on pages 50,
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`51, 52, 53 and 54 of your '647 declaration are
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`figures that you generated using Zemax?
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` A. Yes. I think I also used
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`PowerPoint.
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` That's all I can find right now.
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`There might be some others, but there aren't
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`any figures.
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` Q. Okay. Thank you.
`
` Did you perform any Zemax analysis
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`for these declarations that's not reflected in
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`the declarations themselves?
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` A. There were some intermediate
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`designs. I didn't think that they were
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`relevant to my argument, so I didn't include
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`them.
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` Q. Okay. How much time did you spend
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`working on the declarations that you submitted
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`for these IPRs?
`
` A. I don't know. Probably between 20
`
`and 30 hours.
`
` Q. And is that in total for all three?
`
` A. Yes. It might be a little bit more.
`
` Q. And did you write the declarations
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`that you submitted for these IPRs?
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` A. Yes. I had some help, but they were
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`all under my review.
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` Q. And when you say you had some help
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`with that, I don't want to know any
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`conversations you had with your lawyers, but
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`did you have help from non-lawyers in drafting
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`these declarations?
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` A. There was one person that I asked a
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`little help with for some of the vignetting
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`issue with one of Professor Sasian's Zemax
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`code tables. He wasn't aware of any details
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`with respect to the case, but I asked for a
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`little input on that to make sure that I was
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`correct in my thinking.
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` Q. And who was it that you asked for
`
`help on that point?
`
` A. That was Professor Youngsik Kim.
`
`He's a research professor at the University of
`
`Arizona, College of Optical Sciences.
`
` Q. And when you say vignetting, do you
`
`remember which declaration that would have
`
`been related to?
`
` A. It was when I was looking at
`
`Professor Sasian's implementation of the Ogino
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`Example 5, which I think is in several of the
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`IPRs.
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` Q. And why did you ask Professor Kim
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`for help with the vignetting issue?
`
` A. Well, I just wanted to double-check
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`to make sure that my thinking was correct on
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`the vignetting and setting the surface at true
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`values. And it is.
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` Q. Did Professor Kim agree with your
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`analysis?
`
` A. Yes.
`
` Q. So earlier, you mentioned that you
`
`had done some Zemax work on intermediate
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`designs that you didn't ultimately feel were
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`important enough to include in your
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`declarations.
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` What do you mean when you say an
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`intermediate design?
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` A. Well, typically, there's a fairly
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`logical sequence to go through with designing
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`lenses this complicated. And there's, for
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`example, some steps to go through. I tried to
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`follow Professor Sasian's logic in going, for
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`example, from a 20-degree field of view to a
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`60-degree field of view. And so in doing
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`that, you usually step through a sequence
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`where you gradually increase the field of view
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`in steps. You don't just do it all at once.
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`That sort of thing.
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` Q. So can you describe for me the
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`process of the steps you would take in
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`modifying a lens design, for example, the
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`field of view?
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` A. Could you give me a specific
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`starting point?
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` Q. Well, I guess what are the steps
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`that you went through in trying to evaluate
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`the Ogino lenses for which you generated some
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`intermediate designs in this case?
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` A. Sure. I'd be happy to answer your
`
`question. If you could -- it really does
`
`depend on the starting point. So if you could
`
`be a little bit more specific, it would help
`
`me to answer your question.
`
` Q. Okay. So you mentioned that you
`
`generated some intermediate designs as part of
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`your analysis in these IPRs. Do you remember
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`which lens design was your starting place when
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`you generated those intermediate designs?
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` A. No. The starting point for one of
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`the examples was the Ogino Example 5.
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` Q. Right. So then you said, if I
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`understand your testimony, that there's a
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`process for stepping through modifications for
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`a lens design like Ogino. And I would like to
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`know more about the steps that you took in
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`evaluating Ogino and through which you
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`generate some intermediate designs.
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` A. Yes. Well, if you'd like to, what
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`we can do is go to Bareau and look at that
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`maybe end point for a design. And then we can
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`go to Ogino Example 5 and show the starting
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`point for the design.
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` Q. Okay.
`
` A. So in Bareau, for example -- could
`
`we bring that up?
`
` Q. Yes. Absolutely. I'm going to put
`
`them in the chat. I'm going to load Bareau
`
`and Ogino.
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` Is there anything else you think you
`
`need for this topic?
`
` A. Not right now. But if we need it,
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`we'll get to it.
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` Q. Absolutely.
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` A. So on section 4 of Bareau, there's a
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`table that lists a field of view of 60 degrees
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`and an image circle of 4.6 millimeters, TTL 5
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`millimeters, f/number 2.8. And then there's
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`some distortion in chief ray angle and
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`relative illumination percentage requirements.
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` And Bareau specifies that that's
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`typical for a quarter-inch sensor format and
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`mobile device. And then in Ogino, there's an
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`Example 5 listed. And Example 5 has a -- an
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`f/number of 3.94 and a field angle of 25.9
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`degrees in that field.
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` Q. Sorry, Dr. Milster. What page are
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`you looking at of Ogino, or column?
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` A. One moment, please.
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` So the Figure 5 example is on sheet
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`5 as a diagram.
`
` Q. Okay.
`
` A. And the field angle and f/number are
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`part of the aberration plots on sheet 12 of
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`Ogino. And the lens design values for Example
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`5 are in columns 21 and 22. It doesn't list a
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`sheet number. Table 9 and table 10 are the
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`appropriate tables, I believe.
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` Q. I see those.
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` Okay. So given the information you
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`just pointed out in Bareau and Ogino, what
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`would be the process that you used for
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`modifying those designs that you use in your
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`analysis here?
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` A. I'd like to go back and refer to my
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`declarations just a moment to see which
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`particular way I modified Example 5.
`
` Q. Sure.
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` A. (Witness reviewing document).
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` Okay. So I'm starting on paragraph
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`91 of my '647 declaration. And what I'm
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`showing as a result of the design is the
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`diagram on page 50 of the declaration. So
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`that required -- let me just see -- me to
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`first set the values properly in Zemax and
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`entered Ogino's table first and looked at that
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`performance. Then I decided that I would try
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`a procedure where I first modified the conics
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`and then simplified the aspheric coefficients
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`and went through step-wise to gradually
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`increase the aspheric values -- or the
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`aspheric coefficients, the order of the
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`coefficients in specific -- a specific order
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`going from a lower order to a high order and
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`surfaces, especially the last two, that would
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`improve the performance as specified by the --
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`I think I used an RMS spot radius criterion in
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`my merit function. And that's a step-wise
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`process.
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` And then I wanted to look at the
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`variation of a few surfaces. I don't think
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`that a POSITA would take as careful of an
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`increase as I did, but I wanted to see the
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`influence of especially the first surface
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`curvature of the second lens. And this was in
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`response to Professor Sasian's declaration
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`about the curvature of that surface being
`
`important with respect to vignetting. And
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`what I found was that -- exactly the opposite
`
`of Professor Sasian's conclusions with respect
`
`to the curvature on that surface. And the
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`analysis that I did shows that in fact the
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`vignetting as shown in paragraph 90 of my
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`declaration occurs not near the center, but
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`rather toward the edges outside radii of the
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`lens, which is primarily influenced by the
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`aspherics. That center radius of curvature is
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`more for shortening the focal length, for
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`example, of the system -- or shortening not
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`the focal length, the TTL of the system. And
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`my result showed exactly the opposite
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`conclusion, that the particular meniscus shape
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`that was specified by Professor Sasian is not
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`important at all.
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` And my reasoning is more in line
`
`with what a POSITA would do. If you did have
`
`to take Example 5 and modify it, then my
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`approach is much more logical and would follow
`
`what a POSITA would do than what was described
`
`in Professor Sasian's declaration. I didn't
`
`necessarily agree with that starting point to
`
`begin with, but that was part of my analysis.
`
` Q. And at what part of the process in
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`step-wise changing the aspheric coefficients
`
`did you generate intermediate designs?
`
` A. I didn't hear quite the last part of
`
`your question.
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` Q. Sure. That's okay.
`
` So earlier, you told me that you had
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`generated intermediate designs in Zemax as
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`part of your work in this case. Did you
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`generate those intermediate designs in your
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`work on the 64 declaration that you just
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`described with respect to Ogino Example 5?
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` A. Yes.
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` Q. At what point in that approvals that
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`you just described did you generate the
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`intermediate designs?
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` A. Well, every time that you run the
`
`merit function, you come up with an
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`intermediate design.
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` Q. So each time you change the aspheric
`
`coefficients on a surface, you would run an
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`intermediate design?
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` A. Well, to be specific, the merit
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`function is part of the optimization routine
`
`in the Zemax program. And it wasn't a manual
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`changing of the aspheric coefficients at all.
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`As a matter of fact, I think a POSITA would
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`probably not enter manually those
`
`coefficients. The dependency of the
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`polynomial on the exact values is -- requires
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`a lot of computation, so you wouldn't enter
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`that manually. Those are changed by the
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`optimization routine in Zemax in a very
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`specific way.
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` Q. Okay. But each time the aspheric
`
`coefficient is changed, Zemax would create an
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`intermediate design? Did I understand that
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`correctly?
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` A. Depending on what variables were set
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`in the Zemax algorithm to vary during an
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`optimization cycle. These are placed in the
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`design tables, as you can see. And, for
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`example, in paragraph 91 of my declaration for
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`the '647, you can see that there are four Vs
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`set in this final design table under radius,
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`and then there are five Vs specified under the
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`Conics. And there's a selection of Vs
`
`indicated under the aspheric coefficient.
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` Q. And the inclusion of those Vs
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`indicates that you -- well, what does the
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`inclusion of those Vs indicate?
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` A. When you run the optimization
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`process through Zemax, it will try to change
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`those coefficients. And that procedure is
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`actually pretty complicated on how they figure
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`212-400-8845 - Depo@TransPerfect.com
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`APPL-1028 / Page 28 of 222
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`out how to change them. But those are the
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`variables that are used that the program
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`modifies to find the optimum solution
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`according to the merit function and the way
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`the merit function is set.
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` Q. So what does it mean if there's not
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`a V next to a particular variable in the
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`prescription table on page 54?
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` A. It would mean that that particular
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`value is a constant during the optimization
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`cycle.
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` Q. So, for example, the radius of
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`surface 6 was held constant during that
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`optimization cycle?
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` A. That is correct.
`
` Q. Why did you conclude that the
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`intermediate designs that you generated in
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`that process were not relevant to your
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`declaration?
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` A. Well, for example, if the -- I'm
`
`trying to remember what I used. I looked at
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`several things. I looked at the field
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`curvature and distortion plots. Just a
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`second. It's a little bit dry down here.
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`APPL-1028 / Page 29 of 222
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` Q. Sure.
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` A. The field curvature and disto
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