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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________________________________
` SAMSUNG ELECTRONICS CO., LTD. and
` SAMSUNG ELECTRONICS AMERICA, INC.,
` Petitioners
` v.
` GUI GLOBAL PRODUCTS, LTD., D/B/A GWEE,
` Patent Owner
` __________________________________________
`Case IPR2021-00335, IPR2021-00336, IPR2021-00337 and
` IPR-2021-00338
`U.S. Patent Nos: 10,259,020; 10,259,021; 10,562,077 and
` 10,589,320
` __________________________________________
` DEPOSITION OF MARK N. HORENSTEIN, Ph.D.
` APPEARING REMOTELY
` November 17, 2021
` 10:00 a.m.
`Reported by: Eileen Mulvenna, CSR/RMR/CRR
`____________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2021
`
`202-232-0646
`
`Samsung Exhibit 1031
`Page 001 of 108
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`
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`11/17/2021
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
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`Page 2
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` REMOTE VIDEOTAPED DEPOSITION of
`MARK N. HORENSTEIN, Ph.D., witness on behalf of the
`Patent Owner in the above-titled action, held on
`Wednesday, November 17, 2021, commencing at
`approximately 10:00 a.m., before Eileen Mulvenna,
`CSR/RMR/CRR, Certified Shorthand Reporter,
`Registered Merit Reporter, Certified Realtime
`Reporter, and Notary Public of the State of New
`York.
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
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`Page 3
`
`A P P E A R A N C E S:
`
`ALI R. SHARIFAHMADIAN, ESQUIRE
`ATANAS BAITCHEV, ESQUIRE
`Attorneys for Petitioners
`ARNOLD & PORTER
`601 Massachusetts Ave, NW
`Washington, DC 20001-3743
`202.942.5000
`ali.sharifahmadian@arnoldporter.com
`atanas.baitchev@arnoldporter.com
`
`TAREK FAHMI, ESQUIRE
`JOHN J. EDMONDS, ESQUIRE
`Attorneys for Patent Owner
`COLLINS EDMONDS & SCHLATHER PLLC
`1616 South Voss Road, #125
`Houston, Texas 77057
`281.501.3388
`tarek.fahmi@ascendalaw.com
`jedmonds@ip-lit.com
`
`ALSO PRESENT: Jonah Blum, Exhibit Technician
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`Samsung Exhibit 1031
`Page 003 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 4
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` I N D E X
`WITNESS EXAMINATION BY PAGE
`MARK N. HORENSTEIN, Ph.D.
` MR. SHARIFAHMADIAN 6
` MR. FAHMI 89
`
` E X H I B I T S PAGE
`Exhibit 1010 No Bates numbers, US Patent 63
` Application 2010/0227642
`Exhibit 2005 No Bates numbers, 11
` Curriculum Vitae of Mark N.
` Horenstein, Ph.D.
`
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 5
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` THE REPORTER: Counsel, before
` swearing in the witness, I have a short
` statement to put on the record.
` The attorneys participating in this
` deposition acknowledge that due to the
` severity of COVID-19, I am not physically
` present in the deposition room and that I
` will be swearing in the witness and reporting
` this deposition remotely.
` Do all parties stipulate to the
` validity of this remote swearing and remote
` reporting and that it will be admissible in
` the courtroom as if it had been taken
` pursuant to the applicable rules?
` MR. SHARIFAHMADIAN: Yes, We consent.
` Petitioners consent.
` MR. FAHMI: So stipulated for the
` Patent Owner.
` (Witness sworn.)
`
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 6
`
`DR. MARK N. HORENSTEIN,
` having been duly sworn by Eileen Mulvenna,
` a Notary Public of the State of New York,
` was examined and testified as follows:
`EXAMINATION
`BY MR. SHARIFAHMADIAN:
` Q. Good morning, Dr. Horenstein.
` A. Good morning.
` Q. Could you please state your full name
`for the record.
` A. Mark Nat Horenstein.
` Q. Where are you located today?
` A. Denver, Colorado.
` Q. Are you in a home, an office?
` A. I'm in an apartment. I'm the only one
`here.
` Q. Other than the Zoom program that we're
`using for this deposition, do you have any chat,
`e-mail or other communications programs open on your
`computer?
` A. I do have a browser open. Let me
`close it. And let me close my e-mail program. So
`
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`202-232-0646
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`Samsung Exhibit 1031
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 7
`
`now nothing is open except the Zoom.
` Q. Do you have a smartphone or a tablet
`with you?
` A. Yes.
` Q. Could you turn those off as well while
`we on the record.
` A. Yes. It's in airplane mode. Do you
`want it powered off?
` Q. Just as long as there's no ability to
`receive or send texts or e-mails while we're on the
`record.
` A. There won't be. There isn't.
` Q. Do you have any paper documents with
`you today?
` A. I have copies of my report. They're
`clean copies commensurate with the exhibits that you
`sent to counsel a day or two ago.
` Q. And are there any notes or other
`annotations on the report, the copies that you have,
`that were not in the versions of your reports that
`were served in this case?
` A. No. Like I said, they're clean
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
`Page 007 of 108
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`11/17/2021
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
`
`Page 8
`
`copies.
` Q. Other than the copies of the reports
`themselves, is there anything else that you have
`with you in document form?
` A. Also same situation with a copy of the
`application, also clean copy.
` Q. Anything else?
` A. In the way of documents?
` Q. Yes.
` A. No.
` Q. What about any electronic documents,
`do you have anything open electronically?
` A. No.
` Q. And you agree not to engage in any
`electronic communications while we are on the record
`during this deposition; is that right?
` A. Yes.
` Q. Have you been deposed before, sir?
` A. Yes.
` Q. So you've been through this, but just
`so that we're all on the same page, let me just say
`some of the rules of the road for this deposition.
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
`
`Page 9
` I'm going to be asking you questions
`and I ask that you give verbal answers so that the
`court reporter can take them down. Okay?
` A. Yes.
` Q. And I'll try and do my best to not
`speak over you. I'll let you complete your answers,
`and I would ask that you let me finish the question
`before you begin answering so that the court
`reporter can make a clear record. Is that okay?
` A. Yes.
` Q. If you don't understand any of my
`questions, please let me know and I'll try and ask
`them in a different way or at least clarify. Is
`that okay?
` A. Yes.
` Q. And so if you don't tell me that you
`don't understand, I'll assume that you understood my
`question. Okay?
` A. Correct.
` Q. Is there any reason that you cannot
`give complete, truthful answers to my questions
`today?
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
`Page 009 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
`
`Page 10
`
` A. No.
` Q. You have been retained by Patent
`Owner, GUI, to give declarations in four IPR
`proceedings; is that right?
` A. That's right.
` Q. And do you understand that the
`deposition that we're currently conducting is with
`respect to three of those proceedings?
` A. That's been explained to me.
` Q. All right. So today I'm going to be
`asking you questions that relate to the IPR numbers
`IPR 2021-00336 relating to US Patent 10,259,021, IPR
`2021-3337 relating to US Patent 10,562,077, and IPR
`2021-338, US Patent 10,589,320.
` Is that clear to you?
` A. Yes.
` Q. And it's clear to you that the
`deposition relates to all of those three proceedings
`I just listed?
` A. Right.
` Q. What did you do to prepare for today's
`deposition?
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`Digital Evidence Group C'rt 2021
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`202-232-0646
`
`Samsung Exhibit 1031
`Page 010 of 108
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`
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`11/17/2021
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
`
`Page 11
` A. I read the various documents that
`relate to the IPR and I had some meetings with
`Mr. Fahmi and Mr. Edmonds.
` Q. When did you do this, what date?
` A. It was on two days. One day was
`Monday and another day was -- sorry, I don't quite
`recall. Might have been Friday and Monday. That's
`my best recollection. We had -- we had online
`meetings.
` Q. Roughly speaking, how many hours did
`you spend preparing for your deposition?
` A. I would say 12.
` MR. SHARIFAHMADIAN: Can we -- Jonah,
` could you please bring up Tab 32.
` (Exhibit 2005, No Bates numbers,
` Curriculum Vitae of Mark N. Horenstein,
` Ph.D., received and marked.)
`BY MR. SHARIFAHMADIAN:
` Q. This is a -- this is a copy of
`Exhibit 2005 in the 338 proceeding. Is this a copy
`of your CV, sir?
` A. I can't read it on my screen, but if
`
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`Samsung Exhibit 1031
`Page 011 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
`
`Page 12
`you so stipulate that it's the CV that I submitted
`as part of the IPR, then I will agree to that.
` Q. Okay. Is there anything we can do --
`it's not as critical with this CV necessarily, but
`we will be showing you things on the screen.
` Do you have the ability to review
`documents on a screen and testify about them?
` A. I do. I have a large side screen and
`I just moved the CV document to that screen.
` MR. SHARIFAHMADIAN: All right. So
` maybe, Jonah, you can just flip through it
` and we can just confirm that this is the CV
` that Dr. Horenstein provided.
` (Document review.)
` THE WITNESS: It does appear to be my
` CV as submitted with my IPR declarations in
` this matter.
`BY MR. SHARIFAHMADIAN:
` Q. And is that CV still current?
` A. For the most part. If you go to the
`list of cases in which I have given testimony, I can
`make sure that is up to date.
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
`Page 012 of 108
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`
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
`
`Mark Horenstein, Ph.D.
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`Page 13
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` Scroll down again.
` There's one more case in which I've
`given testimony. I had a deposition in that matter
`last week.
` Q. Which case was that?
` A. It's not on this list because I had
`previously not provided any testimony. It's an IPR
`proceeding and I'm an expert on behalf of Winstar
`America.
` Q. Do you recall the IPR number?
` MR. FAHMI: Objection.
` THE WITNESS: It's not an IPR. It's
` an ITC.
`BY MR. SHARIFAHMADIAN:
` Q. ITC proceeding.
` A. I can look it up in realtime if you
`wish.
` Q. That's okay.
` A. I have the file on my computer.
` Q. No, that's all right.
` ITC proceeding involving Winstar
`America?
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2021
`
`202-232-0646
`
`Samsung Exhibit 1031
`Page 013 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 14
`
` A. Yes.
` Q. You received your Ph.D. in 1978;
`correct?
` A. That's right.
` Q. And since receiving your Ph.D., you've
`worked primarily in academia; is that right?
` A. That's right.
` Q. You worked in industry for one year
`for Spire Corporation from 1978 to 1979; is that
`right?
` A. That's right.
` Q. And since then, since 1979, you've
`been at Boston University?
` A. I was at Boston University until 2020.
` Q. And so from 1979 to 2020, you were a
`professor at Boston University?
` A. That's right.
` Q. And you're a professor emeritus
`currently?
` A. Emeritus, yes.
` Q. What does that mean?
` A. It means that I'm still on the
`
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
`Page 014 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
`
`Page 15
`faculty, but I have no official assignments in the
`way of teaching or research and I am not paid for
`any work that I do.
` Q. So you're not teaching currently?
` A. Not at the present time.
` Q. Are you engaged in research currently?
` A. Yes.
` Q. What is the nature of that research?
` A. It's a project aimed to produce and
`commercialize a system for using electrostatic
`forces to clean dust off the surfaces of solar
`collectors, such as solar panels.
` Q. Is that research through Boston
`University or another organization?
` A. At the present time, it is in
`conjunction with a private company.
` Q. Can you tell us that company?
` A. Sure. It's called Sol Clarity. I'll
`spell it. S-O-L, C-L-A-R-I-T-Y.
` Q. Other than your research you just
`testified about, are you engaged in any other
`research?
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`Samsung Exhibit 1031
`Page 015 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 16
`
` A. Not at the present time.
` Q. What did your research focus on while
`you were at Boston University?
` A. It focused on a variety of topics. I
`would say at least 50 percent or more related to the
`design, production and testing of electronic
`circuits in support of other aspects of the research
`that didn't relate to the electronics.
` Q. And the rest?
` A. My other area of expertise is in
`applied electrostatics.
` Q. Were you engaged in both areas of
`research concurrently the entire time or did you
`change focus from one to the other during your time
`at Boston University?
` A. I always had expertise in both. Any
`research endeavors that related to electrostatics
`also had the design of electronic circuits in
`support of that research associated with them.
`Other projects had nothing to do with
`electrostatics. I was brought on board a research
`team as the electronic design expert.
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
`Page 016 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 17
` Q. In terms of your work on electronic
`circuits, and if I understood you correctly, you
`said it was in support of other aspects of research
`that didn't involve electronic circuits, can you
`just maybe provide a little bit of more explanation
`of what that entailed exactly? What sort of
`electronic circuit are we talking about?
` A. There were many spanning a wide
`variety of circuit types, both including the areas
`of analog electronics, digital electronics, and
`power electronics. For example, I designed a
`multiple channel multiplexer for producing
`high-voltage outputs in the range of several hundred
`volts per channel.
` I over the years designed numerous
`types of driving circuits for MIMS devices. At one
`point, I had to design a temperature controller
`based on analog feedback.
` I can go on, but those three design
`endeavors that I mentioned related to the three
`broad areas of analog electronics, digital
`electronics and power electronics.
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`Digital Evidence Group C'rt 2021
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`202-232-0646
`
`Samsung Exhibit 1031
`Page 017 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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`Page 18
` Q. The multiple channel multiplexer for
`high voltage output that you mentioned, in what
`context would that be used?
` A. Generally as a driver for MIMS or
`microelectromechanical mirrors which require
`voltages on the order of a few hundred volts per
`pixel to create a mirror profile.
` Q. And what sort of products would these
`mirrors be used in?
` A. The main focus of the project on which
`I worked was to deliver a driver for use with a
`large MIMS mirror for exoplanet studies.
` Q. And you mentioned driving circuits for
`MIMS devices. Can you give some examples of the
`types of devices that those driving surfaces would
`be used in?
` A. One driving circuit supported a
`commercial product to drive mirrors that were made
`by the company I was working with.
` Another project was oriented towards
`linearization of MIMS deflection as a function of
`voltage.
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`Digital Evidence Group C'rt 2021
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`202-232-0646
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`Samsung Exhibit 1031
`Page 018 of 108
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`Samsung Electronics Co., Ltd. et al. v. GUI Global Products, Ltd.
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`Mark Horenstein, Ph.D.
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` Another one related to control
`circuitry for plasma deposition of layers required
`to produce a MIMS mirror.
` Q. You mentioned a commercial product to
`drive mirrors. What was that product?
` A. It was a MIMS mirror driver where the
`frequency could be changed from DC or ZERO-hertz all
`the way up to about a kilohertz and produce square
`wave voltages on the order of up to 300 volts with
`variable duty cycle.
` Q. What was the product?
` A. I don't -- I designed it on behalf of
`the company with whom I was working, and I don't
`know what they called the project.
` Q. I see.
` What was the company --
` A. I don't know what -- Boston
`Micromachines.
` Q. What does Boston Micromachines make
`generally?
` A. Deformable mirrors.
` Q. Do you know what those mirrors are
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`used in?
` A. For adaptive optics primarily.
` Q. In what context are those adaptive
`optics products used?
` A. There are many. I know that there are
`commercial products that incorporate an adaptive
`optic mirror for medical imaging, one example,
`particularly looking into the eye to create images
`where the adaptive optic mirror provides -- if you
`reverse distortion of the light that has been
`distorted going in and out of the eye. That would
`be one application.
` Q. So medical devices -- I'm sorry if I
`spoke over you.
` A. That would be one application.
` I also designed circuitry in support
`of a laser range finder communication system for use
`by the American military, and I designed the driving
`circuits and the analog detection circuits for that
`particular product.
` Q. These medical products that these
`adaptive optics components would be used in,
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`generally speaking, do you have a sense for how
`large they are physically?
` A. The entire medical imaging setup or
`the mirror itself?
` Q. Can you answer as to both?
` A. To the first question, I don't know.
`I suspect it's something that's a benchtop size.
`The mirrors themselves are generally on the order of
`1 or 2 centimeters in diameter, either circular or
`rectangular, 1 or 2 centimeters on a side.
` Q. And the laser range finder that you
`mentioned, do you have a sense for how large that
`is?
` A. I do. It was designed to retrofit
`into the sighting scope of a military rifle.
` Q. Into or on a sighting scope?
` A. Incorporated into the sighting scope.
`Sighting scopes today, these days, have built-in
`laser range finders.
` Q. You also mentioned work directed to
`linearization of MIMS deflectors as a function of
`voltage. Again, what sort of products would those
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`components be used in?
` A. Everything I have mentioned so far
`that incorporates an adaptive optic mirror.
` Q. And control circuitry for plasma
`deposition, what sort of products would that be
`incorporated into?
` A. It would be incorporated into a
`laboratory apparatus that does plasma deposition for
`a variety of applications.
` Q. And generally speaking, how large are
`those apparatuses?
` A. Something that stands on the floor and
`it is a meter or two tall. It really depends.
`There are big ones. There are small ones. They're
`used in industry. They're used in research
`laboratories. So there's no -- it's not a
`one-size-fits-all type of machine.
` Q. And your work related to applied
`electrostatics?
` A. Yes.
` Q. Generally speaking, what sort of
`products would that work be incorporated into?
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` A. You're making the assumption that all
`the work in applied electrostatics was oriented
`towards products. A lot of it was oriented toward
`industrial processes which could be used by various
`industries to make whatever they're making.
` For example, electrostatic spray
`painting is a very common application of applied
`electrostatics, and it's used to paint every kind of
`appliance that you can imagine: Cars,
`refrigerators, stoves. Anything that needs to be
`painted nowadays is likely to be painted using
`electrostatic processes. And I did -- I was
`involved in numerous projects related to improving
`and perfecting that particular procedure.
` Another area of research oriented
`towards a product is in the area of self-cleaning
`solar reflectors and mirrors.
` Q. Have you ever designed a consumer
`electronic product?
` A. Yes.
` Q. What was it?
` A. There have been several. One was a
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`meter for use in a laboratory to detect ion
`concentration.
` Another was a device to be used in
`manufacturing processes involving webs. Web and mat
`context means a large sheet of insulating material
`that goes through the processing machine on a
`roll-to-roll basis and because static electricity is
`a problem in those situations, there's a need to
`have products that reduce or eliminate the static
`charge. So I worked on a number of consumer
`products related to that particular problem.
` I also designed the MIMS driver for
`Boston Microelectronics.
` Those are the ones that come to mind
`at the moment.
` I also designed a handheld meter for a
`company called Chapman.
` Q. What was that handheld meter used for?
` A. For measuring surface potential.
` Q. How did it measure that?
` A. The device was about as big as a cell
`phone only somewhat thicker. And inside it had a
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`202-232-0646
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`MOSFET sensor and analog circuitry including sample
`and hold and feedback amplification to produce an
`output that was read by a meter on the face of the
`instrument.
` Q. Who was the target audience for using
`such a device?
` A. The target audience was -- were
`primarily various industries around the world that
`have to worry about surface potential in their
`factories and production facilities from both a
`streamlining production point of view and safety
`point of view.
` These meters are also used by people
`who do forensic inspections and look for buildup of
`static charge; for example, whenever there's any
`kind of explosion in which static electricity is
`suspected, then these meters are widely used in the
`forensic aftermath.
` Q. Who would generally be the purchaser
`of such meters? Would it be companies or
`individuals?
` A. It could be either. I suspect more
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`purchasers would be individuals from companies
`rather than do-it-yourself hobbyists who just want
`to play with the meter, but I suspect there are both
`types of individuals who have interest in such
`meters.
` Q. You said it was the size of a cell
`phone?
` A. Roughly.
` Q. And what was your role in designing
`that product?
` A. Everything starting with the concept
`to the blueprint to the breadboarding to working
`with the company to complete the finished product,
`testing the finished product prototype to work out
`any bugs, and ultimately to use the device myself
`for various purposes to which a device is intended.
` Q. So you worked alone to design the
`products from scratch?
` A. There was any engineer who worked for
`the company, but he didn't know anything about
`electronics. So I didn't work alone, but I was the
`prime mover on that product.
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` Q. Was that product wearable?
` A. No, not designed to be wearable.
` Q. Could it be worn on the wrist?
` A. No.
` Q. Did it have a watch-like form factor?
` A. No.
` Q. Did it have components that could be
`selectively coupled to each other?
` A. I don't know what you mean by that.
` Q. Did it have components that could be
`attached or detached from each other?
` A. Yes.
` Q. What were those components?
` A. The sensor head of the instrument was
`attached to the body of the instrument. That would
`be the primary component that could be detached.
`Also, the circuit board inside the case.
` Q. How was it attached, the sensor head
`to the body?
` A. By a -- as I recall, it's been a
`while, the sensor head had a screw thread on it and
`a large diameter nut was used to attach the sensor
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`www.DigitalEvidenceGroup.com
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`202-232-0646
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`head to the rest -- to the body of the rest of the
`instrument.
` Q. So you'd have to unscrew a screw to
`detach the sensor head from the body?
` A. More or less.
` Q. How would you go about detaching the
`circuit board from the body?
` A. By removing two or more screws.
` Q. You'd have to open the body first?
` A. Yes.
` Q. How would you do that?
` A. By taking off the cover.
` Q. Was it designed to be taken off and
`replaced by the user?
` A. Yes.
` Q. And how would you take off the cover?
` A. By removing, again, a couple of screws
`and taking it off the body.
` Q. To remove the cover, you would have to
`again unscrew several screws?
` A. Right.
` Q. And to remove the circuit board, you
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`would have to unscrew several screws as well?
` A. Right.
` Q. You also referred to a meter for use
`in a lab to detect ion concentration as a
`consumer --
` A. Yes.
` Q. -- electronic product that you
`designed; is that right?
` A. Yes.
` Q. Can you tell me about what that
`product did?
` A. I don't remember the finer points of
`what was inside it. Again, it's been a long while.
`But it had a floating collector plate on which ions
`could impinge and establish a voltage inside the
`instrument which the instrument could then measure.
` Q. Actually, if I could just go back to
`the meter that you designed for Chapman, when did
`you do that work?
` A. In the 1980s through the early 2000s.
` Q. It took 20 years to design the
`prod