UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`YITA, LLC,
`
`vs.
`
`Petitioner,
`
`Patent No. IPR2020-01139
`Patent No. IPR202-01142
`
`MacNEIL IP LLC,
`Patent Owner.
`________________________________
`
`INTERVIEW OF VLADIMIR ORLOV
`via videoconference
`Tuesday, August 3, 2021
`10:06 a.m. EST
`
`Job No.: 389404
`Pages: 1 - 37
`Stenographically Reported By:
`Alison C. Webster, CSR-6266, RPR, RMR, CRR, RDR
`
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`EX1052
`Yita v. MacNeil
`IPR2020-01139
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`YITA, LLC,
`
`vs.
`
`Petitioner,
`
`Patent No. IPR2020-01139
`Patent No. IPR202-01142
`
`MacNEIL IP LLC,
`Patent Owner.
`________________________________
`
`INTERVIEW OF VLADIMIR ORLOV
`via videoconference
`Tuesday, August 3, 2021
`10:06 a.m. EST
`
`Job No.: 389404
`Pages: 1 - 37
`Stenographically Reported By:
`Alison C. Webster, CSR-6266, RPR, RMR, CRR, RDR
`
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`EX1052
`Yita v. MacNeil
`IPR2020-01139
`
`
`
`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`2
`
` A P P E A R A N C E S
`
`ON BEHALF OF THE PLAINTIFF
` STEPHEN MERRILL, ESQUIRE
` JASON A. FITSZIMMONS, ESQUIRE
` Sterne, Kessler, Goldstein & Fox, PLLC
` 1100 New York Avenue, NW, Suite 600
` Washington, D.C. 20005
` 202.371.2600
` smerrill@sternekessler.com
` jfitzsimmons@sternekessler.com
`
`ON BEHALF OF THE PATENT OWNER AND THE WITNESS
` DAVID G. WILLE, ESQUIRE
` Baker Botts, LLP
` 2001 Ross Avenue, Suite 900
` Dallas, Texas 75201
` 214.953.6595
` david.wille@bakerbotts.com
`
`ALSO PRESENT:
`Jeremy Hatfield, Planet Depos tech
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`3
`
` INTERVIEW OF VLADIMIR ORLOV
` Tuesday, August 3, 2021
`
`Q. Hello, Mr. Orlov.
`A. Hello.
`Q. Please state your full legal name.
`A. My name is Vladimir Orlov.
`Q. Thank you.
` And do you understand the purpose of this
` interview today?
`A. Yes, I think so.
`Q. You're here to answer questions about declarations you
` submitted in two cases before the U.S. Patent and
` Trademark Office; is that right?
`A. Yes, that's correct.
`Q. And those case numbers are IPR2020-01139 and
` IPR202-01142; is that correct?
`A. I don't have these numbers in front of me right now,
` but... I think that's correct.
`Q. Have you ever been interviewed for a legal matter
` before, Mr. Orlov?
`A. No, I have not interviewed before for this such
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`4
`
` matter.
`Q. Okay. I'll go over just a few ground rules to keep us
` on the same page. First, I'd ask that you wait until
` the question is finished before you respond to the
` question to make sure we're not speaking over each
` other. Is that okay?
`A. Yeah, sure.
`Q. And second, I'd ask that you speak clearly so that we
` can hear and record your answers rather than using
` gestures or head gestures. Is that okay?
`A. Yeah, I'll do my best. Okay.
`Q. And of you don't understand a question, will you
` please tell me?
`A. Sure.
`Q. If you don't ask to clarify, I'll assume that you
` understood the question; is that okay?
`A. Yeah, okay.
`Q. Counsel for patent owner may object to questions I ask
` from time to time, but unless you're instructed
` specifically not to answer, you'll still need to
` answer the question. Okay?
`A. Yeah, okay.
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`5
`
`Q. Are you under the influence of anything, such as
` medications, that might make it difficult for you to
` understand and answer my questions today?
`A. No, I am not.
`Q. Is there any other reason you cannot provide your
` complete and accurate testimony today?
`A. No, I don't think there is such reason.
`Q. Are you alone today in the room you are in, Mr. Orlov?
`A. Yes, I am.
`Q. And what equipment are you using for the interview
` today?
`A. Just my laptop and, well, screens connected to the
` laptop.
`Q. Do you have a phone with you in the room?
`A. Yes. It's near me, but it's switched off. I mean,
` the sound is switched off.
`Q. And do you agree not to use that phone during the
` questioning today for any reason?
`A. Yes, I do.
`Q. Do you have any hard copies of any documents in front
` of you today?
`A. Yes. I have a copy of my declaration and copy of a
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`6
`
` statement which I am going to sign at the end of the
` interview.
`Q. Any other documents in front of you?
`A. No, I don't have any other documents.
`Q. And the copy of your declaration that you have in
` front of you today, is that marked in the lower
` right-hand corner?
`A. Sorry, can you say again? In which corner it should
` be marked?
`Q. The lower right-hand corner.
`A. No, I don't -- no, there are no marks on it.
`Q. Okay.
` MR. MERRILL: Will the technician pull up
` Exhibit 2031 from the 1139 case, please?
` PLANET DEPOS TECH: Stand by.
`BY MR. MERRILL:
`Q. All right. Mr. Orlov, do you recognize this document?
`A. I mean, I recognize the front page of the document.
` MR. MERRILL: And will the technician
` scroll down slowly through the first three pages of
` the pdf?
`BY MR. MERRILL:
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`7
`
`Q. Mr. Orlov, is this the declaration that you submitted
` in these cases?
`A. Yes, this is a declaration I submitted.
`Q. And on page 3, is that your signature?
`A. Yes, this is my signature.
`Q. And did you sign this document on March 23rd, 2021?
`A. Yes, that's right.
`Q. And you understand that your declaration was submitted
` in two cases?
`A. Yes, I do.
`Q. Are there any differences between these two
` declarations?
`A. Well, I signed only one declaration, so there should
` be no differences between them if there are two
` copies.
`Q. Did you review this declaration in advance of the
` interview today?
`A. Yes, I did.
`Q. When were you first contacted about providing your
` declaration and accompanying translation for this
` case?
`A. It was a few months ago. I can't say the exact date.
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`8
`
`Q. Who contacted you?
`A. First, it was the head of the Moscow branch of Baker
` Botts, Maxim Levinson, who told me that a partner in
` the United States, a partner of our firm, needed an
` interpreter for a meeting.
`Q. Have you worked with Baker Botts before?
`A. Yes, I am employed by Baker Botts.
`Q. How long have you been employed by Baker Botts?
`A. I have been with Baker Botts for more than 15 years.
`Q. Do you do any translation work for anyone other than
` Baker Botts?
`A. You mean during those years?
`Q. During those years, yes.
`A. No. I work only for Baker Botts.
`Q. How are you compensated by Mr. -- by Baker Botts?
`A. I am paid a salary.
`Q. Is that salary dependent on how much translation you
` do?
`A. No. It's a fixed salary which doesn't depend on --
` well, if I work overtime, yeah, it's -- I am paid for
` extra hours. That's how it can depend -- the only
` way the salary can depend on how many hours I work.
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`9
`
`Q. But in general, you're not paid per word you translate
` or page you translate?
`A. No, I'm not.
`Q. Did you write this declaration personally?
`A. No, I didn't. You mean translate -- like I
` translate -- I drive -- you mean declarations signed
` by Ms. Kaminskiene?
`Q. I'm referring just to the declaration, these first two
` pages.
`A. Of course I did write it.
`Q. I'm sorry, you said you did write your declaration,
` these first two pages?
`A. Sorry?
`Q. You said you did write your declaration?
`A. Yes, I did. I thought you were referring to
` Ms. Kaminskiene declaration. That's why I gave a
` different answer.
`Q. Right. Right. For now, I'm just talking about your
` declaration here, these first two pages.
` What was your process for preparing your
` declaration?
`A. The process was that, if I can remember correctly,
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`10
`
` Mr. David Wille ask me some questions about my
` qualification and my experience and I gave him
` answers to those questions. And then -- well, I have
` to recall.
` Then, I think they send me a draft of the
` declaration which reproduced my words, my answers
` exactly. So I -- so every word that I told was
` reproduced in the declaration, so that's...
`Q. About how much time did you spend preparing your
` declaration, not counting the translation?
`A. An hour, maybe. Maybe less.
`Q. Have you ever prepared a translation to be used in the
` U.S. courts or administrative proceeding before?
`A. No, I didn't. No, I didn't.
`Q. So this is your first one?
`A. Yes, it is.
`Q. Did you review your declaration to prepare for today's
` interview?
`A. Very briefly. Just took a look.
`Q. Did you notice any errors in your declaration?
`A. No, I don't think there are any errors in it.
`Q. What else did you do to prepare for today's interview?
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`11
`
`A. I reviewed the declaration of Ms. Kaminskiene and my
` declaration. I think that's it. Yes.
`Q. As part of reviewing Ms. Kaminskiene's declaration,
` did you also review your translation?
`A. I'm sorry, could you repeat the question?
`Q. Sure. As part of reviewing Ms. Kaminskiene's
` declaration, did you also review your translation?
`A. Yes, I looked at it.
`Q. And did you notice any errors in the translation?
`A. No, I have not.
`Q. Did you do anything else to prepare for today's
` interview?
`A. I watched a video on telling how to conduct during
` depositions.
`Q. Did you meet with anyone to prepare for today's
` interview?
`A. No, I didn't.
`Q. And you mentioned a video that you watched telling how
` to conduct during depositions. What video was that?
`A. Just a general video explaining the rules that you
` should stick to during such interviews, depositions.
`Q. Where did you find that video?
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`12
`
`A. It was -- it was sent to me by Mr. David Wille.
`Q. You attended the interview of Ms. Kaminskiene.
` Correct?
`A. Excuse me?
`Q. Did you attend the interview of Ms. Kaminskiene for
` this case?
`A. You mean the one that took place on the 2nd of July?
`Q. I believe that was the date. I don't recall exactly
` the date, but the one that happened on the similar
` Zoom platform.
`A. Yes, I did. I watched, yes, this interview.
`Q. Why did you attend that interview?
` MR. WILLE: So you can answer that to the
` extent it would not reveal any communications with
` counsel. If your sole knowledge of that is based on
` communications with counsel, then I instruct you not
` to answer.
`A. So I will not answer then.
`BY MR. MERRILL:
`Q. What kind of documents do you typically translate into
` Russian?
`A. Legal documents. Contracts. Advice. Opinions.
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`13
`
` Declarations. Statements. All kinds of agreements.
` Deeds. That's all legal documentation that clients
` or lawyers might need.
`Q. So you've translated declarations into Russian before?
`A. I think I did, but it's hard to remember because I've
` translated thousands of documents over all those
` years.
`Q. Have you translated a declaration into Russian that
` had not yet been signed?
`A. I can't say, no. It's -- I just translate a document
` and I don't know what happens to this document
` afterwards. But this is the first time I am in -- I
` think I am involved in such proceedings as this.
`Q. Have you ever translated any patents into Russian?
`A. I don't think so. At least I don't remember. Maybe
` I was doing translations of some, you know, passages,
` excerpts from patents. That's -- that could happen.
` Could have happened in the past. But I don't recall
` now.
`Q. Do you ever translate website pages into Russian?
`A. Yes, I do. When the client needs such translation,
` yeah.
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`14
`
`Q. How much of your work is translating website pages
` into Russian?
`A. I cannot tell you this, you know, percentage-wise,
` but I did -- sometimes I did such translations.
` That's all I can say.
`Q. Have you ever translated any technical papers into
` Russian?
`A. Yes, I did.
`Q. Have you translated any documents in the automotive
` industry into Russian?
`A. I can't recall now. That's not what I normally do.
` Maybe I translated some type -- some type -- such
` documents in the past, but I can't remember now. But
` this is not an area of my explanation.
`Q. Do you have any responsibilities other than
` translating or interpreting at Baker Botts?
`A. No, I don't.
`Q. How many hours a week do you spend translating?
`A. So I work five days a week, seven 1/2 hours a day.
` So if you multiply 35 -- at least 35, 40 hours, 40
` hours a day [sic]. But, of course, there are times
` when I do not do translations because there are no
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`15
`
` assignments. But when there is a busy season, I
` translate -- I do translations 40 hours a week.
`Q. So about how many documents do you translate from
` English into Russian each year?
`A. Each year? Oh, well, it's hard to say, you know.
` Hundreds, I think.
`Q. Are you being paid any additional compensation for
` your time spent on the interview today?
`A. No, I'm not.
`Q. And does your work include interpreting in addition to
` translating?
`A. Occasionally. It's maybe twice a year or even less
` frequently. Mostly translate written texts.
`Q. And when you do interpret, what is the typical context
` for that interpretation?
`A. Could you be more specific? I don't understand the
` question.
`Q. Let me rephrase it for you.
` When you interpret, what is the general
` purpose of those meetings that you are interpreting
` for?
`A. The general purpose of my job in such cases is to
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`16
`
` make sure that both sides of the conversation
` understand each other correctly, so to convey the
` meaning accurately. That's the main purpose of my
` job.
`Q. Are those informal meetings that you interpret for?
`A. Yes. I was interpreting mostly informal meetings,
` yeah.
`Q. Have you ever interpreted for a deposition?
`A. No, I haven't.
`Q. Are you certified to translate from English into
` Russian?
` MR. WILLE: Object to the form of the
` question.
`A. I have a diploma -- a translator diploma which says
` that I am certified to translate, yes. In Russia, I
` am certified to translate.
`BY MR. MERRILL:
`Q. Have you ever --
`A. But what do you mean by "certified"?
`Q. Do you ever translate from Russian into English?
`A. Yes, I do.
`Q. Do you translate into Russian more often than you
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`17
`
` translate into English?
`A. Yes. Yes. Most translations I do are from English
` into Russian.
`Q. About how many documents do you translate from Russian
` into English?
`A. I think --
` MR. WILLE: Objection to the form. Do you
` mean each year or...
` MR. MERRILL: Yeah, I'll rephrase.
`BY MR. MERRILL:
`Q. About how many documents do you translate from Russian
` into English each year?
`A. Depends on the year, but maybe up to a hundred. I
` don't know. Maybe -- some year it may be up to a
` hundred and other year it may be several dozens. But
` there are many documents which I did from English --
` from Russian into English each year.
`Q. Have you been translating documents from Russian into
` English since 1996?
`A. Yes. Sure. Yes.
`Q. Okay. Are there different dialects of Russian?
`A. Dialects? I suppose there are different dialects
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`18
`
` Russian in general, but I translate only into, you
` know, classic version of Russian, not dialects.
`Q. Is the Russian spoken in Lithuania the same as the
` Russian spoken in Moscow?
` MR. WILLE: Object to the form of the
` question.
`A. Well, they have a different accent, I think, but it's
` not a dialect. It's the same Russian. It just
` sounds differently.
`BY MR. MERRILL:
`Q. To your knowledge, has your translation of a document
` ever been challenged in a court or other tribunal
` before?
`A. No, I haven't heard that my translation was
` challenged.
`Q. You graduated in 1990 from the translation department
` of the Moscow State Linguist University; is that
` right?
`A. Yes, that's right.
`Q. What degree did you graduate with?
`A. Degree in translation. That's not -- that's what my
` diploma says, translator of English and French
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`19
`
` languages.
`Q. How long did it take for you to complete your degree?
`A. Five years. It's the standard term study.
`Q. And so you're a translator of the French language as
` well; is that right?
`A. Yeah. For the first three years after my graduation
` I was working as a French translator, but then, after
` that [inaudible] English translate.
` STENOGRAPHER: Mr. Orlov, you kind of cut
` out there. If you can repeat the end.
` MR. ORLOV: Should I say it again?
`A. During the first three years after my graduation, I
` worked as a French translator mostly. But after
` that, from 1996, I have been working as a English
` translator only.
`BY MR. MERRILL:
`Q. So when you say "working as a French translator," do
` you mean translating from French into Russian?
`A. Yes. From French into Russian, from Russian into
` French, and I was doing some interpreting for French
` when coming to Moscow.
`Q. Who was your employer during the time that you worked
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
`
`20
`
` as a French translator?
`A. I worked for Hotel Novotel in Moscow. It was a
` French hotel network. And I worked for an agency, a
` publishing house, who were called Nortekh Imform
` Reklama. And if you want me to spell it, I'll do it.
`Q. If you spell it, would that be in Romanized alphabet
` or would it be in the Russian alphabet?
`A. Romanized.
`Q. Yeah, I think that would be great if you could spell
` that out.
`A. N-o-r-t-e-k-h I-m-f-o-r-m R-e-k-l-a-m-a, Nortekh
` Imform Reklama.
`Q. Did you work for anyone else during the time you
` worked as a French translator?
`A. Yes. I worked for a travel agency briefly, both as
` English and French translator. And as a freelance
` interpreter.
`Q. Did you do that French translation work until 1993,
` then?
`A. From 1993 to 1996, yes.
`Q. So what were you doing for work between 1990 and 1993?
`A. Ah, I'm sorry. Should be some confusion in my mind.
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`Transcript of Vladimir Orlov
`Conducted on August 3, 2021
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`21
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` I graduated in 1990. No. No. Sorry. I am
` completely wrong here. I now recall.
` I worked as a French translator from 1990
` to 1993, those three years. And from 1993, yes, I --
` I think I stopped working as a French translator.
` Yeah, I think so. Sorry, I made a mistake.
`Q. No problem.
` So what were you doing for work between
` 1993 and 1996?
`A. I started working as -- well, I -- all my life I have
` been working as a translator, so I had started
` working as a English translator, I think.
`Q. Is Russian your native language?
`A. Yes, it is.
`Q. How did you learn English?
`A. It was at Moscow Linguistic University, which is
` called Institute of Foreign Languages back then. So
` I was learning English for five years at institute or
` university. And then when I was working as a French
` translator, I understood that -- well, working as a
` first -- working as a French translator was not a
` good option for me. I completed some additional
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`22
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` studies.
`Q. So before you attended the university, did you know
` English?
`A. Yes, I did. Well, I -- I learned English before the
` university. So one of my relatives was teaching
` English.
`Q. The document you translated for this case was the
` declaration of Ms. Kaminskiene; is that correct?
`A. Yes, that's correct.
`Q. Is this document attached as Attachment A to your
` declaration? Sorry, let me strike that.
` Is the document attached as Attachment A to
` your declaration the English version of the
` declaration that you translated?
`A. Yes. Yes, it is.
`Q. Where did you get this document?
`A. Mr. David Wille send it to me for translation.
`Q. And what did you do after you received the document
` from Mr. Wille?
`A. I translated it into Russian and sent to
` Ms. Kaminskiene.
`Q. How long did it take you to translate the document?
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`A. Several hours, I think. It was not that long.
` Several hours.
`Q. Did you do any additional translation after you sent
` it to Ms. Kaminskiene for this case?
`A. I translated some email correspondence between David
` Wille and Janina Kaminskiene.
`Q. Was there any additional translation that you did of
` the declaration itself after you sent it to
` Ms. Kaminskiene?
`A. After Ms. Kaminskiene had completed some declaration
` in Russian, I think I translated it back into
` English, if I remember correctly.
`Q. Were there any changes between the English version
` that you translated into Russian and then the English
` version that you translated back into English?
`A. The Russian, I translated back into English.
` MR. WILLE: Objection to the form.
`BY MR. MERRILL:
`Q. So is it correct that you translated Ms. Kaminskiene's
` declaration from English into Russian and then from
` Russian back into English?
`A. Yes, I translated what the -- she called a template
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`24
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` from English into Russian, and then I translated her
` own declaration, which she completed in Russian, into
` English. So it was a different documents -- or
` document already.
`Q. After translating her declaration which she completed
` in Russian into English, did you then translate it
` back into Russian?
`A. You mean for the third time?
`Q. Right.
`A. No. No, I didn't.
`Q. Did anyone review your translation into English?
`A. What do you mean, "review"? After I complete
` translation, do I review them again?
`Q. Does someone else review your translation once it's
` completed?
` MR. WILLE: Objection to the form.
`A. I think when I do translation for a lawyer, a lawyer
` might review it or might not. It depends on the
` lawyer or the importance of the translation.
`BY MR. MERRILL:
`Q. Do you ever have another translator review your
` translation work?
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`25
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`A. No, I don't. I'm the only translator now at the
` office.
`Q. When you were translating into Russian for this case,
` were there any words you had to look up?
`A. Well, I think I could look up some words, as I
` normally do when I'm doing a translation, so I
` probably did. I think I did, but I can't say now
` which words they were exactly.
`Q. I'll refer you to paragraphs 12 and 13 of your
` declaration.
`A. 12 and 13.
`Q. I'm sorry, paragraphs 12 and 13 of Ms. Kaminskiene's
` declaration. And I'm looking at the English version
` which is on pages 8 and 9.
`A. Uh-huh.
`Q. Do you see the term "firewall" in this paragraph?
`A. Yes.
`Q. Did you have to look up the term "firewall"?
`A. Yes, I think so. Yeah, I had to look it up because
` it's a special term.
`Q. Is there a Russian word --
` [Simultaneous Speaking]
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`26
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`A. Sorry?
`Q. What did you say at the end there? I'm sorry, I cut
` you off.
`A. Yes. I think I had to look it up because it's a
` special term in the automotive industry.
`Q. Is there a Russian word that directly corresponds to
` firewall?
`A. It always depends on the context, but in the context
` of the, you know, car description, car interior,
` there is a term which I used in the translation, yes.
`Q. Do you recall, at Ms. Kaminskiene's interview, her
` referring to a thermal noise insulation piece?
`A. I don't recall.
`Q. Is there another English word that describes the
` Russian term for firewall that you used in your
` translation?
`A. Do you mean another term in Russian, yeah?
`Q. Another term in English.
`A. In English. Maybe not, but I need to check it. I
` can't say for sure.
`Q. Those paragraphs also include the term "footwell."
` Do you see that?
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`A. Yes, I do.
`Q. Did you have to look up the term "footwell" for your
` translation?
`A. No, I didn't. Because I already knew the translation
` of this word before I -- before I started this
` translation.
`Q. Do you see, in paragraph 15, the term "trim piece"?
`A. Yes, I do.
`Q. Did you have to look up "trim piece" for your
` translation?
`A. I think I translated this term into Russian using the
` parts catalog which was attached to the declaration.
`Q. Were there other words that you used the parts
` catalog -- strike that.
` Were there other words that you translated
` into Russian by referring to the parts catalog?
`A. I can't say for sure. I don't recall. I do remember
` about this term, sill trim, because there was a
` picture of it, a screenshot, and that's why I do
` remember about this one.
` But I don't recall if I -- which terms I
` translated using the parts catalog.
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`Q. Where did you get --
` [Simultaneous Speaking]
`Q. Where did you get the parts catalog?
`A. I think Mr. David Wille provided it to me, send it to
` me by email. Or it was part of the correspondence
` between. Maybe Ms. Kaminskiene sent it. I don't
` recall exactly.
`Q. The Kaminskiene declaration includes three exhibits;
` is that correct?
`A. Let's see. You mean... I'm not sure. Probably. I
` cannot check right now, but I guess it has.
` MR. MERRILL: If the technician would pull
` up Exhibit 2031 again.
` PLANET DEPOS TECH: Stand by.
` MR. MERRILL: And go to page 13, please.
`BY MR. MERRILL:
`Q. Do you see Exhibit A, Mr. Orlov?
`A. Yes, I do.
` MR. MERRILL: And if the technician would
` scroll down through the next two pages.
` I'm sorry, it's just one page. Go to
` page 14, please.
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`BY MR. MERRILL:
`Q. Do you recognize Exhibit A?
`A. Yes, I do.
`Q. Did you translate the English language of Exhibit A to
` the Kaminskiene declaration into Russian?
`A. No, I didn't. It was already in two languages, in
` English and Russian. That's the screenshot I was
` referring to when I said that didn't have to look up
` the trim -- trim set in the dictionary because I had
` this screenshot.
`Q. Do you recall if you translated any of the exhibits
` from English into Russian?
`A. No, I didn't translate any exhibits. I mean, I
` didn't translate parts catalog and I didn't translate
` this one. Were there any other exhibits?
`Q. Yeah.
` MR. MERRILL: If the technician would go to
` page 142. And scroll down to the...
`A. Ah, there's a third exhibit.
`BY MR. MERRILL:
`Q. Do you recognize Exhibit C, Mr. Orlov?
`A. Yes, I saw it before.
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`30
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`Q. And if you look at your declaration, Mr. Orlov, in
` paragraph 7 and 8 --
`A. 7 and 8.
`Q. -- you indicate that you did not translate Exhibit B
` or Exhibit C; is that correct?
`A. Yes, that's correct.
`Q. Is there any statement in your declaration of whether
` or not you translated Exhibit A?
`A. And what is Exhibit A exactly, then? I must be sure
` that I...
`Q. Exhibit A was the one we looked at, page 13 and 14.
` The technician can pull it up for you.
`A. This one which is on screen now?
`Q. Correct.
`A. No, I didn't translate it either.
`Q. And is there a statement in your declaration
` indicating that you did not translate Exhibit A?
`A. I'm not sure about this. I don't think so. I don't
` think there are any reference to Exhibit A in my
` declaration. I only translated Ms. Kaminskiene's
` declaration. That's all I translated.
`Q. So you did not translate any content in Exhibit B.
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`31
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` Correct?
`A. No, I didn't.
`Q. And is that because Exhibit B includes Russian and
` English descriptions of the relevant content?
`A. Yes. I think so, yeah.
`Q. Did you verify that the Russian and English
` descriptions in Exhibit
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