UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - x
`YITA LLC
`
`v.
`
`Case Nos.
`Petitioner,
`IPR2020-01139, IPR2020-01142
`U.S. Patent Nos.
`8,382,186 and 8,833,834
`MACNEIL IP LLC,
`Patent Owner.
`- - - - - - - - - - - X
`
`REMOTE DEPOSITION OF TIM A. OSSWALD, PH.D.
`August 5, 2021
`
`Reported by:
`MARY F. BOWMAN, RPR, CRR
`JOB NO. 389431
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`EX1049
`Yita v. MacNeil
`IPR2020-01139
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - - - - - - - - x
`YITA LLC
`
`v.
`
`Case Nos.
`Petitioner,
`IPR2020-01139, IPR2020-01142
`U.S. Patent Nos.
`8,382,186 and 8,833,834
`MACNEIL IP LLC,
`Patent Owner.
`- - - - - - - - - - - X
`
`REMOTE DEPOSITION OF TIM A. OSSWALD, PH.D.
`August 5, 2021
`
`Reported by:
`MARY F. BOWMAN, RPR, CRR
`JOB NO. 389431
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`EX1049
`Yita v. MacNeil
`IPR2020-01139
`
`
`
`Transcript of Tim A. Osswald, Ph.D.
`Conducted on August 5, 2021
`
`2
`
` August 5, 2021
` 11:00 a.m.
`
` Remote deposition of TIM A. OSSWALD,
`PH.D., held before Mary F. Bowman, a Registered
`Professional Reporter, Certified Realtime Reporter,
`and Notary Public of the State of New Jersey.
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`Transcript of Tim A. Osswald, Ph.D.
`Conducted on August 5, 2021
`
`3
`
` APPEARANCES: (BY VIDEOCONFERENCE)
`
`ON BEHALF OF PETITIONER:
`JASON A. FITZSIMMONS, ESQUIRE
`STEPHEN MERRILL, ESQUIRE
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
` 1100 New York Avenue, NW, Suite 600
` Washington, DC 20005
` (202) 371-2600
`
`ON BEHALF OF PATENT OWNER:
`CLARKE STAVINOHA, ESQUIRE
`DAVID G. WILLE, ESQUIRE
`BAKER BOTTS LLP
` 2001 Ross Avenue, Suite 900
` Dallas, Texas 75201-2980
` (214) 953-6595
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`Transcript of Tim A. Osswald, Ph.D.
`Conducted on August 5, 2021
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`4
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` APPEARANCES: (BY VIDEOCONFERENCE)
`
`ON BEHALF OF PATENT OWNER:
`TIMOTHY M. SCHAUM, ESQUIRE
`DASPIN & AUMENT, LLP
` 300 South Wacker Drive, Suite 2200
` Chicago, Illinois 60606
` (312) 258-3792
`
`Also Present:
`Lucas Shaker, A/V Technician
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`Transcript of Tim A. Osswald, Ph.D.
`Conducted on August 5, 2021
`
`5
`
` INDEX:
`WITNESS EXAM BY: PAGE:
`T. Osswald Mr. Fitzsimmons 6, 214
` Mr. Stavinoha 201
`
` EXHIBIT INDEX:
` Newly marked:
`NUMBER DESCRIPTION PAGE:
`Exhibit A diagram 176
`
` EXHIBIT INDEX:
`Previously marked but displayed during deposition:
`NUMBER DESCRIPTION PAGE:
`2024 Popp Declaration 153
`2041 Osswald Declaration 14
`2060 U.S. Patent 4,181,780 79
`1001 U.S. Patent 8,382,186 121
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`Transcript of Tim A. Osswald, Ph.D.
`Conducted on August 5, 2021
`
`6
`
`TIM A. OSSWALD, PH.D.,
` called as a witness by the parties,
` having been duly sworn, testified as follows:
`EXAMINATION BY
`MR. FITZSIMMONS:
` Q. Good morning, Mr. Osswald.
` Could you state your full legal name
`for the record?
` A. Tim Andreas Osswald. Andreas is
`A-N-D-R-E-A-S, and Osswald with two S's.
` Q. I am Jason Fitzsimmons at Sterne,
`Kessler, Goldstein & Fox on behalf of the
`petitioner, Yita, LLC, in these matters.
` Do you understand that you are having
`your deposition taken today in connection with two
`inter-partes review matters at the U.S. Patent and
`Trademark Office?
` A. Correct.
` Q. And the declaration that you submitted
`for those matters, it's the same for both
`proceedings, correct?
` A. Correct.
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`Conducted on August 5, 2021
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`7
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` Q. And just for the record, the case
`numbers in those matters, it's IPR2020-01139 and
`IPR2020-01142.
` Do those sound correct to you?
` A. Yes.
` Q. And these proceedings involve two
`patents. One of them is U.S. 8,382,186. And the
`other is U.S. 8,833,834.
` Does that sound correct to you?
` A. Yes.
` Q. And I'll refer to those patents by the
`last three digits, the '186 and '834 patent.
` Is that fine with you, Dr. Osswald?
` A. Yes.
` Q. Is it your understanding that MacNeil
`IP, LLC is a patent owner of these two patents?
` A. Yes.
` Q. And you understand that Yita, LLC is
`the petitioner in these matters, correct?
` A. Correct.
` Q. Have you heard of Yita before working
`on this case?
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`Conducted on August 5, 2021
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`8
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` A. No.
` Q. You provided declarations for legal or
`administrative proceedings before, correct?
` A. Yes.
` Q. How many declarations have you
`provided before?
` A. I don't know. Many. Many
`declarations.
` Q. Do you have a ballpark estimate?
` A. No.
` Q. Do you think it's more than 20?
` A. Probably more -- I don't know, maybe
`around 50. I don't know. Maybe more than that.
` Q. Somewhere around 50 sounds about
`right?
` A. Or more. I don't know. I don't
`remember. I haven't counted.
` Q. OK.
` Have you ever provided a declaration
`in a legal proceeding related to vehicle floor
`trays before?
` A. No.
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`Conducted on August 5, 2021
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`9
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` Q. When was the most recent -- other than
`this case, obviously -- time that you provided a
`declaration for a legal or administrative
`proceeding?
` A. Maybe four weeks ago or so.
` Q. Have you provided a declaration before
`in an inter-parte review matter?
` A. Yes.
` Q. Do you know what the technology was in
`those matters?
` A. Cell phone cases.
` Q. Any others?
` A. I don't remember. I mean -- yeah, I
`mean -- I don't recall. Yes, there have been
`others, but I don't remember. That's the one that
`comes to mind.
` Q. OK. And have you ever worked for
`MacNeil before --
` A. No.
` Q. -- this case?
` A. No.
` Q. And you've been deposed before,
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`Conducted on August 5, 2021
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`10
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`correct?
` A. Correct.
` Q. Do you know how many times you've been
`deposed?
` A. I don't know. Maybe between 50 --
`over 50 times. I don't know.
` Q. When was the most recent time that
`you've been deposed?
` A. A couple of months ago.
` Q. Now, I'll go over my ground rules.
`Obviously, you're experienced with the process
`here today. I'll just run through some things
`quickly here.
` You understand that you are under oath
`today, correct?
` A. Yes.
` Q. I just ask that you try to speak
`clearly and answer with words and not hand
`gestures or nodding, in particular, because we are
`in a remote environment today. And then I'll also
`ask that you please try to wait until my question
`is finished before you begin answering.
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`11
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` Does that sound fair?
` A. Yes.
` Q. If you don't understand a question,
`will you please tell me?
` A. Yes.
` Q. And, sir, if you don't ask me to
`clarify a question, I'll assume that you have
`understood it. Is that right?
` A. Correct.
` Q. So counsel for patent owner may from
`time to time object to questions, but you
`understand that you still need to answer my
`questions unless specifically instructed not to.
`Is that right?
` A. Yes.
` Q. I'll try to take a break about every
`hour, except if there is a question pending, I ask
`that you answer the question before we take break.
`Is that fair?
` A. OK.
` Q. Do you understand that you cannot
`confer with counsel during the deposition today,
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`Conducted on August 5, 2021
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`12
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`right?
` A. Yes, I understand that.
` Q. Are you under the influence of
`anything, such as medication, that might make it
`difficult for you to understand and answer my
`questions today?
` A. No.
` Q. Is there any other reason that you
`can't provide your complete and accurate testimony
`today?
` A. No.
` Q. And since we are having this
`deposition remotely, may I ask just where you're
`located today, Dr. Osswald?
` A. I am in Madison, Wisconsin.
` Q. At -- sorry, you said in your office?
` A. Yes.
` Q. And are you alone?
` A. Yes.
` Q. What equipment are you using to take
`part in this deposition today?
` A. A laptop.
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`Conducted on August 5, 2021
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`13
`
` Q. Do you have a phone with you?
` A. Yes, I do. It's turned off.
` Q. And I ask that you just please keep
`that off for the remainder of the deposition.
` Do you have any hard copies of
`documents with you today?
` A. Yes.
` Q. And what documents do you have?
` A. I have my report. I have the --
`copies of '186 and the '834 patents. I have a
`Yung or Yang -- Yung, Y-U-N-G, reference. I have
`the Rabbe patent, R-A-B-B-E. I have the Popp
`translation, P-O-P-P, of the Rabbe patent. And I
`have the Dawson translation of the Rabbe patent.
` Q. OK. And do you have any other
`documents there with you?
` A. No, I don't.
` Q. I saw that you had Post-it notes with
`what looked like the name of the documents on
`there. Is that correct?
` A. Correct.
` Q. Are there any other notes or writing
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`14
`
`on those documents that you have with you?
` A. No.
` Q. OK. So those are all clean copies of
`the documents?
` A. Correct.
` Q. Thank you.
` You said that you had your report with
`your declaration there with you. Which matter
`number is that report for?
` I don't know if they are the same but
`if you could just let me know.
` A. It just says, "Declaration of Tim A.
`Osswald, Ph.D."
` Q. Maybe on the first page there, the
`bottom right-hand corner, is there a proceeding
`number?
` A. No, there isn't. It's just ...
` Q. OK. Just briefly, I would like the
`technician to please pull up Exhibit 2041 from
`both proceedings, the 1139 and the 1142
`proceeding, and then we will just stick with one
`of these since they are the same.
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`Conducted on August 5, 2021
`
`15
`
` MR. FITZSIMMONS: Could you please
` pull those up on the screen, Lucas?
` TECHNICIAN: Absolutely. Please
` stand by.
` 2041 is up.
` MR. FITZSIMMONS: Thank you.
` Can you go to the 1139 document
` first?
` Thank you.
` Can we just scroll to the table of
` contents?
` There we go.
` Q. Dr. Osswald, do you recognize the
`document here on the screen?
` A. Yes.
` Q. This is Exhibit 2041 in the 1139
`proceeding. And if we can go to page 140 of the
`PDF.
` If we could go down a couple more. It
`will be 140 at the bottom of the page.
` There we go. So it's PDF page 144.
`It says page 140 at the bottom.
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`Conducted on August 5, 2021
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`16
`
` Is this your signature here on this
`document, Dr. Osswald?
` A. Yes.
` Q. And did you sign this on May 4, 2021?
` A. Yes, it must have been.
` Q. And then let's just go over to the
`other declaration in the 1142 proceeding.
` Do you recognize this document as
`well, Dr. Osswald?
` A. Yes.
` Q. We can scroll through again to the
`signature page. It should be page 144 of the PDF.
` Is that your signature there,
`Dr. Osswald?
` A. Yes.
` Q. And then these declarations are
`identical, correct?
` A. Correct.
` Q. So we will just -- we can close the
`1142 document. We will just work in the 1139
`document today for convenience.
` Is that fine with you, Dr. Osswald?
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`Conducted on August 5, 2021
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`17
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` A. That's fine.
` Q. I would like to talk a little bit now
`about your preparation of this declaration,
`Dr. Osswald.
` What was your process for preparing
`this declaration?
` MR. STAVINOHA: So I'll just caution
` the witness not to reveal any communications
` with counsels. The parties have agreed that
` those are not discoverable in these
` proceedings.
` You can answer the question,
` Dr. Osswald.
` A. Obviously, I reviewed the patents. I
`reviewed all the other references that were
`brought into this IPR, and then I got a general
`structure from the attorneys.
` I filled in the blanks. I wrote things,
`and we iterated back and forth. I'm not a lawyer,
`so some things have to be written in a more clear
`fashion, not a technical fashion. But everything
`that is in there is my opinion.
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`Conducted on August 5, 2021
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`18
`
` Q. It sounds like you typed -- personally
`typed some of this declaration but not other
`portions. Is that correct?
` A. Correct.
` Q. And about how much total time would
`you say you spent preparing this declaration,
`including review of materials and exhibits?
` A. Yeah, I don't know. I think -- I
`don't know, over 50 hours, maybe 70. I don't -- I
`have not added them together.
` I know I've been -- I've worked quite a
`bit on this case, but for the declaration, maybe 50,
`70 hours, I don't know, maybe more.
` Q. And you mentioned that you reviewed
`some materials in advance of preparing this
`declaration or while preparing this declaration,
`and in your declaration here, paragraph 22, if we
`go to that, there is a section called "Materials
`Considered." It should be on page 13 of the PDF.
` And so on -- it's paragraph 22,
`Dr. Osswald, "Materials Considered," there is a
`table here listing a number of documents that
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`spans on to what is PDF page 18 of this document.
`It's also page 14 at the bottom.
` Do you see that?
` A. Yes.
` Q. And did you review all of these
`materials listed in the table?
` A. Yes.
` Q. About how long would you say you spent
`reviewing these materials listed in the table?
` A. I don't know. I don't remember.
` Q. Can you give an estimate?
` A. I don't know. I'm a pretty fast
`reader and all that, but I don't know, it took a
`long time.
` As I said, I think, in this case, I
`probably have worked around 100 hours, and I don't
`know how long it took me in each individual
`reference.
` Q. OK. Exhibit 1008 that's listed on
`there, do you see that is a book called
`"Technology of Thermoforming."
` If we can go on the screen to
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`Exhibit 1008. Where it shows it, it will be on
`PDF page 14.
` Do you see that Exhibit 1008,
`Dr. Osswald?
` A. Yes, I do.
` Q. And that's the Throne book or one of
`the Throne books, correct?
` A. Correct.
` Q. And you reviewed that book, is that
`right?
` A. I'm familiar with that book. That's a
`book that I read on and off throughout the years.
` Q. Specifically for this case, did you
`review that book?
` A. Yes, I paged through it.
` Q. What do you mean by "paged through
`it"?
` A. I looked at it.
` Q. Would you say that you skimmed that
`document?
` A. Yeah, I mean, I'm familiar with
`Dr. Throne's writing in this book. In fact, at
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`one point, I was going to translate it into
`Spanish, so I'm familiar with the book.
` Q. In reviewing for this case, did you
`skip some portions of that document or did you
`read the entire thing?
` A. I skipped some portions. And, again,
`I know where to find things, table of contents, et
`cetera, indices, so I looked at it.
` But I didn't read the whole book for
`this case. I've read the book before.
` Q. So it sounds like you were familiar
`with this book prior to this case, is that
`correct?
` A. Correct.
` Q. Do you consider it a reputable
`resource?
` A. Yes.
` Q. And also listed here right above it,
`Exhibit 1007, is the Gruenwald book.
` Do you see that, Doctor?
` A. Yes, I see it.
` Q. Did you review that book for this
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`case?
` A. Yes.
` Q. Did you review all of that book?
` A. I didn't read the whole -- again, I'm
`familiar with Gruenwald's book as well from
`previous works. This is what I do.
` Q. I see. So the Gruenwald book is one
`that you were familiar with before your work on
`this case, is that right?
` A. Correct.
` Q. Do you consider that book a reputable
`source as well?
` A. Yes.
` Q. And if we look here also at the
`"Materials Considered" list, do you see
`Exhibit 1005, what we -- is called the Rabbe,
`R-A-B-B-E?
` A. Yes.
` Q. And then also, Exhibit 1006, Yung,
`Y-U-N-G?
` A. Yes.
` Q. And Exhibit 1011, Sturtevant, do you
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`see that one as well?
` A. Yes.
` Q. In addition to the Gruenwald book,
`that collection of four documents are the
`references that are applied in the petition,
`correct?
` A. Correct.
` Q. And you don't dispute that those
`documents are prior art to the '186 and '834
`patents, correct?
` A. Correct.
` MR. STAVINOHA: Objection to form.
` Q. And you mentioned that you've reviewed
`the Throne book -- again, Exhibit 1008 --
`previously.
` Do you know Dr. Throne personally?
` A. I mean, I'm not friends with him.
`I've seen him in conferences here and there.
` Q. So you have met him before?
` A. Yes.
` Q. And have you spoken with him before?
` A. I'm sure we have. I mean, there are
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`so many people in our field, but yeah, I'm sure I
`have said "Hi" to him, and I think when we talked
`about a translation of this book into Spanish a
`few years back.
` Q. When was the last time that you can
`recall speaking to him?
` A. I don't remember.
` Q. Was it within the last year?
` A. No.
` Q. And you understand that Dr. Throne
`submitted a declaration in these proceedings,
`which is Exhibit 2004, correct?
` A. Correct.
` Q. And you reviewed that declaration in
`both proceedings, the 1139 and the 1142
`proceeding?
` A. Yes.
` Q. And then you also list on here
`Exhibit 2042, the declaration of Ryan Granger.
` Do you see that one, Dr. Osswald?
` A. Yes.
` Q. Did you review a confidential or
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`redacted version of that declaration?
` A. I think it was redacted. There was
`some black areas in there, as I recall.
` Q. And your rate here, as stated in your
`declaration, I believe is 650 dollars an hour, is
`that correct?
` A. Correct.
` Q. Is that your standard consulting rate?
` A. Yes.
` Q. Since when has that been your
`consulting rate?
` A. I don't remember.
` I have one case that I'm working on
`where I charge 600, which was before I raised, but I
`think since last year.
` Q. Is that your rate for today's
`deposition, 650?
` A. Yes.
` Q. When were you first contacted about
`consulting for these matters?
` A. I think at the beginning of this year
`sometime. I don't remember, actually. I would
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`have to go back and look at my records.
` Q. You think sometime early in 2021
`sounds about right?
` A. Yes, sometime in the spring.
` Q. Who first contacted you about these
`matters?
` A. Let me see, I think Tim Schaum
`contacted me.
` Q. And when you were preparing your
`declaration, who were you working with on that?
` MR. STAVINOHA: I'll just, again,
` caution the witness not to reveal any
` communications with counsel.
` A. Yeah, I mean, I would send my drafts
`to the group of attorneys. So I think --
` Q. Do you remember who was in that group
`of attorneys?
` A. Yeah. David Wille was in the group.
`Clarke Stavinoha, and I'm sure I messed up the
`last name there. I think Tim Schaum was also
`included, and then Jeff -- Jefferson Perkins was
`also included.
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` I don't know, there may have been other
`people included, but I don't remember.
` Q. Have you had any discussions with
`anyone at MacNeil or WeatherTech?
` A. Yes.
` Q. Who is that?
` A. We went for a tour to see the plant,
`et cetera, maybe two weeks ago or so.
` Q. And do you know who at WeatherTech you
`met with?
` A. Yeah, Ryan -- Ryan -- the name -- last
`name slips my -- the one who wrote that one
`report.
` Q. Ryan Granger?
` A. Yes, correct.
` Q. Anyone else?
` A. No, not from MacNeil. He was the only
`one from MacNeil that was there.
` Q. OK. And you said you went on a tour
`of the MacNeil or WeatherTech facilities, is that
`right?
` A. Yes.
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` Q. And about two weeks ago?
` A. Yes.
` Q. So that was after you submitted your
`declaration, correct?
` A. Yes.
` Q. And what was the purpose of that
`visit?
` A. It was just to look at the one Lada
`Niva and just the -- I'm always interested in
`touring a plant. We looked at the plant, and it's
`always fun to see that.
` Q. You mentioned that you looked at the
`Lada Niva.
` That's the vehicle that's mentioned in
`your declaration, correct?
` A. Correct.
` Q. And what did you do when you were
`looking at the Lada Niva?
` A. We inspected the inside, moved the
`seats around, just took a look at it.
` I mean, I've sat in Lada Nivas before.
`They are all the same, basically. Looked under the
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`hood. Just checked it out, the back seat area, the
`trunk area.
` Q. And why did you do that?
` A. Just to see it. I mean, just to make
`sure that I had with my own eyes seen the Lada
`Niva where the scans were taken.
` Q. Again, you looked at that vehicle,
`though, after preparing your declaration, correct?
` A. Correct. I've seen the scans of the
`vehicle and it was the same vehicle, the same from
`the photographs that I saw in the Granger report.
` Q. You mentioned also about -- that while
`you were at the WeatherTech facility, I think you
`said you looked at the manufacturing part of the
`plant, is that right?
` A. Correct. We saw both the
`manufacturing facilities, but also, the mold
`making, the rapid prototyping area, an area where
`they have the scan where they have some parts that
`they are showing -- I mean, that they are
`analyzing.
` So just in general, had a tour of the
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`site -- of the campus.
` Q. So with manufacturing facilities, it
`sounds like the mold making and the rapid
`prototyping and the sort of scanning areas are all
`in one location, is that right?
` A. Well, they are different buildings,
`but yeah, it was all in one location. We drove to
`that, yes, correct.
` Q. In the '186 and '834 patents, the
`inventors are David MacNeil and Scott Vargo,
`correct?
` A. Correct. Correct.
` Q. Do you know David MacNeil?
` A. I don't.
` Q. Have you ever met David MacNeil?
` A. I have not. Not that I remember. I
`don't think I've ever met him. I would have
`remembered, I'm sure.
` Q. Do you know Scott Vargo?
` A. No. Again, not that I remember.
` Q. Sure.
` And I want to switch gears a little
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`bit. We have been talking mostly about preparing
`the declaration. I want to turn now to preparing
`for today's deposition.
` So you prepared for the deposition
`today, is that right, Dr. Osswald?
` A. Yes.
` Q. And what did you do to prepare for the
`deposition today?
` A. I read my report. I looked at all the
`references. I -- not all of them but a lot of the
`references. I met with the attorneys a couple of
`times, one time last week, one time this week.
` Q. When you say the "attorneys," which
`attorneys did you meet with?
` A. Mr. Stavinoha, Mr. Wille, Jefferson
`Perkins. I believe Tim Schaum was on the phone as
`well. I don't remember if they were there both
`times but he was also -- he was there yesterday.
` Q. You said once this week and once last
`week, is that correct?
` A. Correct.
` Q. And it sounds like the meeting this
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`week was yesterday, based on your last answer, is
`that right?
` A. Yes.
` Q. Was that meeting in person or via
`phone or video conference?
` A. Video conference.
` Q. And the meeting last week, was that
`also video conference?
` A. Yes.
` I think it was last week. Yeah, I
`think -- yeah, this was -- yeah. Also video
`conference, correct.
` Q. And about how long were each of those
`meetings?
` A. Let me see. Last week, I think we had
`planned to do it all day and it was less than a
`morning. It was less than three hours.
` And yesterday, we had planned for three
`hours, and it took about that.
` Q. So you said you reviewed your
`declaration and a lot of the references.
` Do you recall which references you
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`specifically reviewed?
` A. I reviewed -- I reviewed the '186, the
`'834, the Rabbe translations, the Yung reference,
`Y-U-N-G. There is also a Y-A-N-G reference.
` I looked at the -- at the Shearman
`deposition. I read through that. I read through
`the Popp deposition. I read through the Granger
`deposition and their reports.
` In general, just refreshing my memory
`with all the different references and depositions
`and reports.
` Q. So it sounds like you reviewed the
`deposition transcript from Mr. Shearman's
`deposition, is that correct?
` A. Correct.
` Q. And you also reviewed the transcript
`from Dr. Popp's deposition, is that correct?
` A. Correct.
` Q. And you also reviewed a transcript
`from Mr. Granger's deposition, is that correct?
` A. Yes.
` Q. Where did you receive those
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`transcripts from?
` A. I don't know. I don't remember who
`sent them to me.
` Q. Was it the attorneys in this case?
` A. Maybe, I don't know. I'm not sure,
`yeah.
` I know one of them was Mr. Shearman's,
`and I received it from one of the attorneys.
` Q. Did you review those transcripts?
` A. Yes.
` Q. I'm sorry. My question was: Why did
`you review those transcripts?
` A. To prepare for today, to see -- to
`understand your style. I mean, that's usually
`what I do in a deposition, know who the attorney
`who is going to question me, what their style is
`and all of that.
` Q. And you also reviewed your
`declaration.
` Did you notice any errors while
`reviewing your declaration?
` A. No, I don't recall seeing any.
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` Q. If you notice any errors today, do you
`agree to tell me?
` A. Yes.
` Q. And if your opinion changes on
`anything that's stated in your declaration based
`on our discussions today, do you agree to tell me?
` A. Yes.
` Q. Dr. Osswald, you're currently a
`professor at the University of Wisconsin, is that
`right?
` A. Correct.
` Q. What classes do you teach there?
` A. I teach many classes.
` I teach an introductory course, a
`required coarse, in polymer processing and
`manufacturing of plastics products, which is taught
`to seniors. Every mechanical engineering student
`takes that.
` I teach a class in engineering design
`with polymers. So that's an elective, but it's one
`that many, many students take.
` I teach a class in introduction to
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`polymer composites.
` I teach a course in additive --
`introduction to additive manufacturing or suite
`printing.
` Most of those, I have actually developed
`the courses.
` I teach a course in modeling and
`simulation in polymer processing, an advanced
`course.
`
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