No, 379847
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C. -v- MacNeil IP L.L.C. (PTAB)
`Returnto: transcripts@planetdepos.com
`
`
`Page|Line Correction/Change and Reason
`
`
`
`“deposition” should be “declaration”
`
`
`I misspoke
`
`“chop” should be “shop”
`Transcription error (TE)
`
`
`
`
`
`
` Replace answerwith, “I think I stated that
`
`Clarification
`
`Add to end of answer, “We consistently
`meet those standards other than when a
`manufacturer
`builds
`vehicles with
`significant variations
`in the shape or
`dimensions of their footwells.
`Those
`tolerances are better than the standard for
`close conformance set forth in the ‘186
`Patent.”
`
`
`“Line 41” should be “Paragraph 41”
`
`I misspoke
`
`95 percent of the S&Usat least meet one
`of the claims with respect
`to the ‘834
`Patent. That is what I said in Paragraph 42
`of my declaration.
`I also said that 100%
`of WeatherTech’s floor liners meet Claim
`1 of the ‘186 Patent.”
`
`
`
`
`The
`Clarification.
`question was confusing
`because it mixes up what
`I said in my declaration
`about
`the ‘186 Patent
`with what I said about
`the ‘834 Patent.
`
`
`
`
`
` Clarification.
`Replace answer with “T mean it meets at
`The
`question continues the
`least one of our claims in the ‘834 Patent.
`That is the patent for which I said in my
`confusion from a prior
`declaration that 95% of the SKUs meetat
`question. As I note in
`the
`correction
`above,
`least one of the claims.”
`that
`question
`was
`confusing
`because
`it
`mixes up what I said in
`my declaration about the
`‘186 Patent with what I
`
`Yita v. MacNeil IP, IPR2020-01139, Page 1
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 1
`
`
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C. -v- MacNeil IP L.L.C. (PTAB)
`Returnto: transcripts@planetdepos.com
`
`
`Page|Line Correction/Change and Reason
`
`
`
`“deposition” should be “declaration”
`
`
`I misspoke
`
`“chop” should be “shop”
`Transcription error (TE)
`
`
`
`
`
`
` Replace answerwith, “I think I stated that
`
`Clarification
`
`Add to end of answer, “We consistently
`meet those standards other than when a
`manufacturer
`builds
`vehicles with
`significant variations
`in the shape or
`dimensions of their footwells.
`Those
`tolerances are better than the standard for
`close conformance set forth in the ‘186
`Patent.”
`
`
`“Line 41” should be “Paragraph 41”
`
`I misspoke
`
`95 percent of the S&Usat least meet one
`of the claims with respect
`to the ‘834
`Patent. That is what I said in Paragraph 42
`of my declaration.
`I also said that 100%
`of WeatherTech’s floor liners meet Claim
`1 of the ‘186 Patent.”
`
`
`
`
`The
`Clarification.
`question was confusing
`because it mixes up what
`I said in my declaration
`about
`the ‘186 Patent
`with what I said about
`the ‘834 Patent.
`
`
`
`
`
` Clarification.
`Replace answer with “T mean it meets at
`The
`question continues the
`least one of our claims in the ‘834 Patent.
`That is the patent for which I said in my
`confusion from a prior
`declaration that 95% of the SKUs meetat
`question. As I note in
`the
`correction
`above,
`least one of the claims.”
`that
`question
`was
`confusing
`because
`it
`mixes up what I said in
`my declaration about the
`‘186 Patent with what I
`
`Yita v. MacNeil IP, IPR2020-01139, Page 1
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 1
`
`
`
`No. 379847
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C. -v- MacNeil IP L.L.C, (PTAB)
`Return to: transcripts@planetdepos.com
`
`
`
`about
`said
`Patent.
`
`the
`
`‘834
`
`
`
`
`
`
`
`
`AQ 9-12|Replace answer with, “In my opinion, at
`Clarification. Again, the
`question was confusing
`least 95 percent of the SKUs or models of
`the WeatherTech FloorLiner floor tray
`because it mixes up what
`
`product
`line molded between 2004 and
`I said in my declaration
`
`now meet at least one of the tolerance
`about
`the ‘186 Patent
`
`
`requirements of the ‘834 Patent Claims |,
`with what I said about
`
`5, and 9 as stated in Paragraphs 43-44 of
`the ‘834 Patent. When I
`
`my declaration. My opinion with respect
`asked for the attorney to
`point me to where I
`to the ‘186 Patent
`is
`that 100% of
`
`WeatherTech’s floor liners meet Claim 1
`talked about 95% in my
`
`of the ‘186 Patent as stated in Paragraph
`declaration, he pointed
`
`42 of my declaration.”
`me to Paragraph 44 that
`
`is
`talking
`about
`the
`
`tolerance
`requirements
`
`of Claims 1, 5, and 9 of
`
`the
`‘834
`Patent
`as
`
`
`discussed in Paragraph
`
`43 of my declaration. So
`the
`attorney
`was
`apparently
`asking
`a
`
`question about the ‘186
`Patent Claim 1
`but
`
`pointed me
`to
`a
`in
`paragraph
`my
`
`declaration where I was
`talking about
`the ‘834
`Patent.
`
`
`40 17-|Replace answer with, “Correct. As it
`
`Clarification.
`The
`question is confusing. It
`18|stated there in Paragraph 44, at least one of
`the tolerance requirements. That is all I
`is not clearif it is asking
`am talking about
`in that paragraph.
`me about what is being
`However, in Paragraph 42, I note that 95%
`said in paragraph 44
`
`
`
`Yita v. MacNeil IP, IPR2020-01139, Page 2
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 2
`
`
`
`No. 379847
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C, -v- MacNeil IP L.L.C. (PTAB)
`Returnto: transcripts@planetdepos.com
`
`
`
`of the SKUs will be covered by atleast one|(which is how I
`
`of Claims 1, 5, and 9 of the ‘834 Patent.”|interpreted the question)
`or asking me about my
`opinion in general.
`I
`clarified my answer to
`address
`either
`possibility.
`
`
`
`
`
`
`46 Replace answer with “Forty-Nine out of|Clarification.4 The
`
`fifty, meaning 98%”
`question asked for
`a
`percentage and I gave an
`absolute value.
`
`
`
`
`
`
`
`55
`
`61
`
`65
`
`3
`
`7
`
`6
`
`TE
`“charge” should be “large”
`
`
`“Meso”should be “Ezzo”
`
`TE
`
`“420” should be “0.120”
`
`Clarification
`
`125|12-|“bearing” should be “varying” TE
`
`
`16
`
`“To be; Clarification
`Add to the end of the answer:
`clear, the walls are going to be somewhat
`thinnerthan the original sheet thickness as
`a person skilled in the art would expect
`with any thermoforming process.”
`
`
`
`128|7-10|“obviously” should be “obvious” TE
`
`
`128|21-|Add to end of answer, “What I mean by;Clarification
`22|that is that it will depend upon what the
`person knows about thermoforming. Any
`person of ordinary skill in the art looking
`at
`the WeatherTech products would
`conclude that for the portions of the trays
`that
`the patent claims
`require to be
`uniformly thick that they are uniformly
`
`Yita v. MacNeil IP, IPR2020-01139, Page 3
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 3
`
`
`
`No, 379847
`
`
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C, -v- MacNeil IP L.L.C. (PTAB)
`Return to: transcripts@planetdepos.com
`
`
`thick just by looking at them. It is obvious
`to a person skilled in the art that nothing
`was done to make the part
`thicker or
`thinner in those locations and that any
`small variations
`are
`typical of
`the
`thermoforming process.”
`
`
`Clarification
`
`Add to end of answer, “Another reason I
`am certain of that is that the VIN number
`on the VIN plate matches the VIN number
`that is stamped into a component of the
`vehicle—specifically a sheet metal part
`inside of the engine compartment.”
`
`
`based upon the overall proportions and Clarification
`
`
`
`Add to end of answer, “When you use the
`term “match” I am not sure how you are
`using the term. One part of the confusion
`is that the drawings showafloortray and
`the scan shows a footwell. They are not
`supposed to “match” The floor tray is
`supposed to fit inside of the footwell of a
`Lada Niva. Another point of confusion is
`that it is not clear if you are asking about
`dimensions. As I stated in my declaration
`in paragraph 114, Rabbe recites no
`dimensionsfor his floortrays. So it is not
`possible to match the heights of an
`undimensioned drawing to a scan. But as
`I also stated in my declaration, one can
`obviously see the overall proportions and
`shapes of Rabbe’s trays from his drawings.
`It
`is obvious when looking at
`those
`drawings
`that
`the floor
`trays
`in the
`drawings were designed for a Lada Niva
`
`
`
`Yita v. MacNeil IP, IPR2020-01139, Page 4
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 4
`
`
`
`
`
`
`No, 379847
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C. -v- MacNeil IP L.L.C. (PTAB)
`Return to: transcripts@planetdepos.com
`
`shapes of the drawings as compared to my
`scans.
`
`
`
`
`answer makesclear.
`
`“scans” should be “floortrays”
`I misspoke
`
`Bither TE or I misspoke
`as the remainder of my
`
`“isn’t” should be “is”
`
`
`
`Clarification
`
`Add to answer, “I want to be clear that
`what I compared in my analysis was the
`shapes of the Lada Niva footwell
`(as
`illustrated by the scans) to the shapes of
`the Rabbe floortrays (asillustrated by the
`scans),
`I view that as different
`than
`comparing a drawing to a scan. Also, the
`drawing is at a specific profile angle of 45
`degrees and it would have been very
`difficult to get a scan that was oriented at
`the exact same angle.”
`
`
`
`
`“Womac” should be “Womack”
`
`
`TE
`
`
`
`
`
`
`
`
`Yita v. MacNeil IP, IPR2020-01139, Page 5
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 5
`
`
`
`No. 379847
`
`Re: Deposition of Ryan Granger
`Date: 7/1/2021
`Case: Yita L.L.C. -v- MacNeil IP L.L.C. (PTAB)
`Returnto: transcripts@planetdepos.com
`
`DECLARATION OF DEPONENT
`
`IT, Ryan Granger, do hereby acknowledge that
`
`I have
`
`read and examined the foregoing testimony, and the same
`
`is a true, correct and complete transcription of
`
`the
`
`testimony given by me and any corrections appear on the
`
`above Errata sheet which is a part of this declaration.
`
`I declare under penalty of perjury that the foregoing is
`
`true and correct. Executed on the date indicated below.
`
`Signature
`
`
`
`Yita v. MacNeil IP, IPR2020-01139, Page 6
`
`MacNeil Exhibit 2189
`
`MacNeil Exhibit 2189
`Yita v. MacNeil IP, IPR2020-01139, Page 6
`
`
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