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` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`ADVANCED ENERGY INDUSTRIES INC.,
`PETITIONER,
`
`V.
`
`RENO TECHNOLOGIES INC.,
`PATENT OWNER.
`________________________________
`Case IPR2021-01397
`Patent 10,707,057
`________________________________
`HIGHLY CONFIDENTIAL
`ATTORNEYS EYES ONLY
`August 10, 2022
`________________________________
`
`Videotaped deposition of JOHN VOLTZ,
` taken via Zoom, beginning at 10:17 a.m.,
` before LINDA ROSSI-RIOS, a Federally Approved
` Registered Professional Reporter, Certified
` Court Reporter and Notary Public.
`
`- - -
`VERITEXT LEGAL SOLUTIONS
`MID-ATLANTIC REGION
`1801 Market Street - Suite 1800
`Philadelphia, PA 19103
`
`Veritext Legal Solutions
`346-293-7000
`
`Page 1
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`ADVANCED ENERGY INDUSTRIES INC.,
`PETITIONER,
`
`V.
`
`RENO TECHNOLOGIES INC.,
`PATENT OWNER.
`________________________________
`Case IPR2021-01397
`Patent 10,707,057
`________________________________
`HIGHLY CONFIDENTIAL
`ATTORNEYS EYES ONLY
`August 10, 2022
`________________________________
`
`Videotaped deposition of JOHN VOLTZ,
` taken via Zoom, beginning at 10:17 a.m.,
` before LINDA ROSSI-RIOS, a Federally Approved
` Registered Professional Reporter, Certified
` Court Reporter and Notary Public.
`
`- - -
`VERITEXT LEGAL SOLUTIONS
`MID-ATLANTIC REGION
`1801 Market Street - Suite 1800
`Philadelphia, PA 19103
`
`Veritext Legal Solutions
`346-293-7000
`
`Page 1
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
`
`
`
` A P P E A R A N C E S :
`
` O n b e h a l f o f A d v a n c e d E n e r g y I n d u s t r i e s
` P O L S I N E L L I , P C
` B Y : J A M E S P . M U R P H Y , E S Q U I R E
` 1 0 0 0 L o u i s i a n a S t r e e t
` S u i t e 6 4 0 0
` H o u s t o n , T e x a s 7 7 0 0 2
` j p m u r p h y @ p o l s i n e l l i . c o m
`
` - A N D -
`
` G R E G O R Y D U R B I N , E S Q U I R E
` 1 4 0 1 L a w r e n c e S t r e e t
` S u i t e 2 3 0 0
` D e n v e r , C o l o r a d o 8 0 2 0 2
` g d u r b i n @ p o l s i n e l l i . c o m
`
` O n b e h a l f o f R e n o T e c h n o l o g i e s I n c .
` B A K E R & H O S T E T L E R L L P
` B Y : J E F F R E Y W . L E S O V I T Z , E S Q U I R E
` 1 7 3 5 M a r k e t S t r e e t ,
` S u i t e 3 3 0 0
` P h i l a d e l p h i a , P e n n s y l v a n i a 1 9 1 0 4
` j l e s o v i t z @ b a k e r l a w . c o m
`
` A L S O P R E S E N T :
`
` A L A N W A L T E R , A S M
`
` J O S E P H M I L L E R , E S Q U I R E
` T h e B e l l e s G r o u p P C
`
` D A V I D N O R D H E I M E R , V i d e o g r a p h e r
`
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`1 9
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`Page 2
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
`
`
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` I N D E X
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` W I T N E S S P A G E
`
`J O H N V O L T Z
`
` B Y M R . M U R P H Y 8 , 5 8
`
` B Y M R . L E S O V I T Z 5 5
`
` E X H I B I T S
`
` M A R K E D D E S C R I P T I O N P A G E
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`E x h i b i t 2 0 1 1 C o n f i d e n t i a l 1 8
` D e c l a r a t i o n
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`1 0
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`Veritext Legal Solutions
`346-293-7000
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`Page 3
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` - - -
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` COURT REPORTER: The attorneys
`
` participating in this deposition
`
` acknowledge that I am not physically
`
` present in the deposition room, and
`
` that I will be reporting this
`
` deposition remotely.
`
` They further acknowledge that in
`
` lieu of an oath administered in person,
`
` I will administer the oath remotely.
`
` If any party does have an
`
` objection to this manner of reporting,
`
` please state so now.
`
` (No objections.)
`
` - - -
`
` VIDEOGRAPHER: We are now on the
`
` record. Please note that the
`
` microphones are sensitive and may pick
`
` up whispering and private conversations.
`
` Please turn off all cell phones and
`
` place them away from the microphones as
`
` they can interfere with the deposition
`
` audio. Recording will continue until
`
` all parties agree to go off the record.
`
`Veritext Legal Solutions
`346-293-7000
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`Page 4
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` My name is David Nordheimer,
`
` representing Veritext. The date today
`
` is August 10, 2022, and the time is
`
` approximately 10:17 a.m.
`
` This deposition is being held
`
` virtually via Zoom and -- Mr. Voltz
`
` what city are you physically located in
`
` right now?
`
` THE WITNESS: Lahaska,
`
` Pennsylvania.
`
` VIDEOGRAPHER: Lahaska. The
`
` witness is in Lahaska, Pennsylvania.
`
` This deposition is being taken by
`
` counsel for the petitioner.
`
` The caption of the case is
`
` Advanced Energy Industries,
`
` Incorporated, Petitioner, versus Reno
`
` Technologies, Incorporated, Patent
`
` Owner. The case is being held before
`
` The Patent Trial and Appeal Board of
`
` the United States Patent and Trademark
`
` Office. Case Number IPR 2021-01397,
`
` Patent 10,707,057.
`
` The name of the witness is John
`
`Veritext Legal Solutions
`346-293-7000
`
`Page 5
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
`
`
`
` Voltz.
`
` At this time, the attorneys
`
` attending remotely will identify
`
` themselves and the parties they
`
` represent.
`
` MR. MURPHY: This is James
`
` Murphy, Polsinelli PC. I represent
`
` Advanced Centering Industries. And on
`
` the call with me is my partner Greg
`
` Durbin, also with Polsinelli PC.
`
` MR. LESOVITZ: This is Jeff
`
` Lesovitz from Baker Hostetler,
`
` representing Reno Technologies,
`
` Incorporated, the patent owner.
`
` MR. MILLER: Joe Miller,
`
` representing Reno from the Belles
`
` Group.
`
` MR. WALTER: This is Alan
`
` Walter. I represent ASM.
`
` VIDEOGRAPHER: Our court
`
` reporter, Linda Rossi-Rios,
`
` representing Veritext, will swear in
`
` the witness and we can proceed.
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`Page 6
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` - - -
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` JOHN VOLTZ, after having been
`
` duly sworn, was examined and testified
`
` as follows:
`
` - - -
`
` THE WITNESS: James, I can't see
`
` you on video.
`
` MR. MURPHY: Let me see if I can
`
` turn on the Teams one.
`
` Just for the record, we're
`
` having some technical issues.
`
` Mr. Voltz is not able to appear over
`
` the Zoom video, and so we are trying to
`
` do the deposition over Zoom while
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` having a video feed between myself,
`
` Mr. Lesovitz and Mr. Voltz on a
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` separate Teams chat.
`
` Mr. Voltz, I'm not sure if I can
`
` get the video to work with both Zoom
`
` and Teams at the same time. I think
`
` it's the same problem Jeff was having a
`
` minute ago.
`
` Do you need to see me on the
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` video to have your deposition taken
`
`Veritext Legal Solutions
`346-293-7000
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`Page 7
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` today?
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` THE WITNESS: I think it's fair.
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` MR. MURPHY: Okay. Then I guess
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` we'll have to postpone this deposition
`
` then because I don't see a workaround.
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` MR. LESOVITZ: Mr. Voltz, I have
`
` the same issue. I can't have a camera
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` on for both Teams and Zoom at the same
`
` time. How about we proceed, and if it
`
` becomes an issue, Mr. Voltz, you can
`
` mention it at the time. I think it
`
` should be okay proceeding without the
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` video. If you have any questions or
`
` want clarification for a question that
`
` Mr. Murphy asks, you can feel free to
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` do that during the deposition.
`
` THE WITNESS: Okay. Thanks
`
` Jeff.
`
` - - -
`
` EXAMINATION
`
` - - -
`
` BY MR. MURPHY:
`
` Q. So are you good to have your
`
` deposition taken today, then, Mr. Voltz, given
`
`Veritext Legal Solutions
`346-293-7000
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`Page 8
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` the limitations we have?
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` A. Let's proceed.
`
` Q. Have you ever had your deposition
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` taken before, Mr. Voltz?
`
` A. Yes.
`
` Q. How many times have you been
`
` deposed before?
`
` A. I'm not sure.
`
` Q. Do you have a rough estimate?
`
` Is it one to two, five to ten?
`
` A. Three to five.
`
` Q. So the testimony you're going to
`
` give today is under oath just the same as you
`
` would give before a court. Are you aware of
`
` that?
`
` A. Yes.
`
` Q. Is there any medical or health
`
` reason that would prevent you from giving a
`
` full, complete, true testimony today in this
`
` deposition?
`
` A. No.
`
` Q. So for the three to five
`
` depositions that you did previously, were they
`
` all related to your employment at Reno
`
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`Page 9
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` Sub-Systems?
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` A. No.
`
` Q. Were any of them related to your
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` employment at Reno Sub-Systems?
`
` A. No.
`
` Q. Were any of them related to
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` cases involving patents?
`
` A. I don't think so. I don't
`
` recall any.
`
` Q. Were any of them related to any
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` products manufactured by Reno Sub-Systems?
`
` A. No.
`
` Q. What did you do to prepare for
`
` today's deposition?
`
` A. Could you be more specific?
`
` Q. How much time did you spend
`
` preparing for today's deposition?
`
` A. Between 30 and 60 minutes.
`
` James, let me clarify, are you
`
` asking me personally, how much time I
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` personally did?
`
` Q. Yes, the time that you
`
` personally spent.
`
` A. Several hours total.
`
`Page 10
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` Q. So you spent several hours
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` preparing for today's deposition?
`
` A. In total, yes.
`
` Q. Did you meet with anyone to
`
` prepare for today's deposition?
`
` A. Yes.
`
` Q. Who did you meet with?
`
` A. Jeff, Joe, and Alan.
`
` Q. When did you meet with Jeff,
`
` Joe, and Alan?
`
` A. Monday and yesterday. I'm
`
` sorry, this morning.
`
` Q. Jeff, Joe, and Alan you referred
`
` to are the same Jeff, Joe, and Alan attending
`
` this deposition. Is that right?
`
` A. Yes.
`
` Q. And how long were those meetings
`
` with Jeff, Joe, and Alan?
`
` A. Well, candidly, a lot of the
`
` time was spent with this execution with Zoom
`
` and Teams. In terms of the substance, not
`
` very much.
`
` Q. What do you mean by not very
`
` much in terms of the substance?
`
`Page 11
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`Veritext Legal Solutions
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` MR. LESOVITZ: I'm going to
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` object as privileged and advise the
`
` witness not to disclose the substance
`
` of any communications that you had with
`
` your attorneys. Otherwise, if you can
`
` answer without doing that, you can
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` proceed.
`
` THE WITNESS: I don't think I
`
` can answer without going through what
`
` our discussions were.
`
` BY MR. MURPHY:
`
` Q. Mr. Voltz, I'm just asking at
`
` the moment how much time did you spend in the
`
` meeting with Jeff, Joe, and Alan on the
`
` substance of your declaration?
`
` A. I don't know for sure.
`
` Q. Can you provide an estimate of
`
` how much time you've spent meeting with Jeff,
`
` Joe, and Alan on the substance of your
`
` declaration?
`
` A. I couldn't be sure.
`
` Q. Was it more than a few hours
`
` that you spent meeting with them?
`
` A. I didn't have a stopwatch going,
`
`Page 12
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` James.
`
` Q. So you have no idea how much
`
` time you spent talking to them?
`
` A. What you asked me --
`
` MR. LESOVITZ: Objection. Asked
`
` and answered.
`
` THE WITNESS: I'm sorry?
`
` MR. LESOVITZ: Objection. Asked
`
` and answered.
`
` BY MR. MURPHY:
`
` Q. Mr. Voltz, you can still answer
`
` the question. If your attorney objects, you
`
` still need to answer.
`
` A. What exactly is the question,
`
` James?
`
` Q. You don't know how long you met
`
` with Jeff, Joe, and Alan in your meeting
`
` yesterday?
`
` A. Yes, I do.
`
` Q. How long did you meet with Jeff,
`
` Joe, and Alan in your meeting yesterday?
`
` A. About three hours. It wasn't
`
` yesterday. It was Monday.
`
` Q. And then how long did you meet
`
`Page 13
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` with Jeff, Joe, and Alan this morning?
`
` A. 25 minutes or so.
`
` Q. Who contacted you to prepare a
`
` declaration in this proceeding?
`
` MR. LESOVITZ: Objection.
`
` Privileged. I'm instructing the
`
` witness not to answer.
`
` MR. MURPHY: What is the
`
` privilege objection there, Jeff?
`
` MR. LESOVITZ: To the extent he
`
` was contacted by an attorney, that goes
`
` into the substance of a communication
`
` with an attorney.
`
` MR. MURPHY: The fact that he
`
` was contacted is privileged? I'm not
`
` asking about the content.
`
` MR. LESOVITZ: The way you
`
` framed your question, it implicated the
`
` content. If you can ask the question a
`
` different way, it doesn't request the
`
` content of the communication, I suggest
`
` you try it that way.
`
` MR. MURPHY: I'll try to
`
` rephrase it then.
`
`Page 14
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
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` BY MR. MURPHY:
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` Q. Mr. Voltz, what was the name of
`
` the individual who contacted you to provide a
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` declaration in this proceeding?
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` A. I believe it was Alan Walter who
`
` first contacted me about it.
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` Q. What did Alan Walter ask you to
`
` prepare a declaration about?
`
` MR. LESOVITZ: Objection.
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` Privileged. I'm instructing the
`
` witness not to answer.
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` MR. MURPHY: And what is the
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` objection?
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` MR. LESOVITZ: The objection is
`
` that any request to Mr. Alan would have
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` been at the direction of an attorney
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` and could have possibly included the
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` conversation with an attorney.
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` BY MR. MURPHY:
`
` Q. Mr. Voltz, is Mr. Alan your
`
` attorney?
`
` A. His name is Alan Walter, and no.
`
` Q. I apologize. Is Mr. Walter your
`
` attorney?
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` A. No.
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` Q. So I'll ask again. What did
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` Mr. Walter ask you to prepare a declaration
`
` regarding?
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` MR. LESOVITZ: So I'm going to
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` object as privileged. You can answer
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` that question provided that there was
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` not an attorney present or on the
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` phone, if it was a phone call.
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` Otherwise, you're free to answer.
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` THE WITNESS: I believe you
`
` asked who first contacted me about this
`
` issue. It was Alan Walter. And his
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` ask was if I would be willing to be a
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` witness and be deposed.
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` BY MR. MURPHY:
`
` Q. And did Alan discuss with you
`
` the content of the information he would like
`
` you to put in your declaration on that phone
`
` call?
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` MR. LESOVITZ: Same objection.
`
` Same objection, privileged. If there
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` was an attorney present during that
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` conversation, I instruct you not to
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` answer. Otherwise, you may answer,
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` provided you know for a fact that an
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` attorney was not present.
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` THE WITNESS: There was an
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` attorney on the call.
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` MR. LESOVITZ: Then I'm going to
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` maintain my objection and instruct the
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` witness not to answer.
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` BY MR. MURPHY:
`
` Q. Mr. Voltz, who was the attorney
`
` on the call from your recollection?
`
` A. Joe Miller.
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` Q. Mr. Voltz, were you employed at
`
` Reno Sub-Systems at the time you received that
`
` call?
`
` A. No.
`
` Q. Just for clarity of the record,
`
` let me ask again because I don't believe there
`
` is a valid objection here, but, Mr. Voltz, can
`
` you tell me what Mr. Walter asked you to
`
` provide in terms of substance for your
`
` declaration during that call?
`
` MR. LESOVITZ: Objection.
`
` Attorney-client privilege. I'm
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`Exhibit 1027
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` instructing the witness not to answer.
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` - - -
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` (Exhibit 2011, Confidential
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` Declaration, marked for identification.)
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` - - -
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` BY MR. MURPHY:
`
` Q. Mr. Voltz, why don't we have you
`
` take a look at your declaration. If you can
`
` access the Exhibit Share feature. There
`
` should be two versions of your declaration in
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` there, a confidential and non-confidential
`
` one. I think we can have you look at the
`
` confidential version. Let me know when you're
`
` able to access that and have it open.
`
` A. Which one did you say, the
`
` confidential one?
`
` Q. Yes.
`
` A. Okay. I can see it.
`
` Q. If you scroll through that
`
` document, you don't see any black redaction
`
` boxes, do you?
`
` Are you still looking at the
`
` document, Mr. Voltz?
`
` A. I am. It's got to load. There
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` is a lot going on in my box here.
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` Q. Take your time and let me know
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` when you get a chance to review it.
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` A. On pages 1 through 5 I do not
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` see any redaction.
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` Q. If you go to the cover page of
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` it, and you look at the bottom, does it say
`
` Reno Exhibit 2011?
`
` A. Yes.
`
` Q. If you go to the very last page
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` of this document, there is a signature there.
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` Is that your signature?
`
` A. Yes.
`
` Q. When you signed this document,
`
` you agreed under penalty of perjury that all
`
` the statements in your declaration were true
`
` and correct. Is that right?
`
` A. Yes.
`
` Q. Did you review this document
`
` when preparing for your deposition today?
`
` A. Yes.
`
` Q. When you reviewed that document,
`
` did you discover any errors or mistakes that
`
` you would like to correct?
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` A. No.
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` Q. Did you prepare this declaration
`
` by yourself?
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` A. Yes.
`
` Q. So you wrote the whole
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` declaration on your own?
`
` A. I didn't format it.
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` Q. All the words in the declaration
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` were written by you?
`
` A. Yes.
`
` Q. Did any attorneys help in the
`
` preparation of your declaration?
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` MR. LESOVITZ: Objection. Asked
`
` and answered.
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` I also object as privileged and
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` instruct the witness you can answer
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` that yes or no. But just to advise
`
` you, you should not disclose any
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` communications that you had with your
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` attorneys.
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` THE WITNESS: Please repeat the
`
` question, James.
`
` BY MR. MURPHY:
`
` Q. Did any attorneys help you in
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` preparing your declaration?
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` MR. LESOVITZ: Same objection
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` and instruction.
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` BY MR. MURPHY:
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` Q. Are you able to answer that
`
` question, Mr. Voltz?
`
` A. No, I'm not.
`
` Q. You're not able to answer
`
` because you don't know if an attorney helped
`
` you prepare your declaration or not?
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` A. I've been instructed not to
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` answer the question, James.
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` Q. I believe --
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` MR. LESOVITZ: Just to clarify
`
` my instruction, Mr. Voltz, you can
`
` answer the question yes or no. But my
`
` instruction was otherwise don't
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` disclose any communications that you
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` may have had with attorneys.
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` Mr. Murphy, do you want to ask
`
` the question again and I'll do the same
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` instruction to make it clear?
`
` MR. MURPHY: Sure.
`
` BY MR. MURPHY:
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` Q. Mr. Voltz, did any attorney help
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` you prepare your declaration?
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` MR. LESOVITZ: Objection.
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` Privileged. You can answer yes or no.
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` THE WITNESS: Yes.
`
` BY MR. MURPHY:
`
` Q. Mr. Voltz, let's go to your
`
` background. Your educational background is in
`
` marketing and other business degrees. Is that
`
` right?
`
` A. Yes.
`
` Q. You don't have any degrees in
`
` engineering or other technical field, do you?
`
` A. No.
`
` Q. You started working for Reno
`
` Sub-Systems in January 2018. Is that right?
`
` A. Yes.
`
` Q. Can you provide a list of
`
` companies that you worked at prior to Reno
`
` Sub-Systems?
`
` A. Sure. Solid State Equipment
`
` Corporation. Mattson Technology. Genus,
`
` Incorporated. Matrix Integrated Systems.
`
` Silicon Valley Group.
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` Q. Is that it, Mr. Voltz, or are
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` you still thinking?
`
` A. Yeah, I mean, there's a few
`
` others, but those are the highlights.
`
` Q. Did any of those companies sell
`
` RF matching networks?
`
` A. No.
`
` Q. Do you currently have any equity
`
` interest in Reno Sub-Systems?
`
` A. No.
`
` Q. And I believe Reno Sub-Systems
`
` recently got acquired by ASM America. Is that
`
` right?
`
` A. Yes.
`
` Q. Do you have any equity interest
`
` in ASM America?
`
` A. Not that I know of.
`
` Q. Are you aware if you have any
`
` equity interest in an affiliated company of
`
` Reno Sub-Systems?
`
` A. Not that I know of.
`
` Q. Are you aware if you have any
`
` equity interest in an affiliated company of
`
` ASM America?
`
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` A. Again, not that I know of.
`
` Q. Are you being compensated for
`
` the time you provide working on this
`
` declaration you provided?
`
` A. Yes.
`
` Q. And is any of that compensation
`
` dependent on the outcome of this proceeding?
`
` A. No.
`
` Q. What was your job role at Reno
`
` Sub-Systems?
`
` A. Officially I had two titles
`
` during my tenure; the first was Vice President
`
` Global Sales and the second was Senior Vice
`
` President of Business Development in the
`
` Office of the President.
`
` Q. So were you in charge of all of
`
` Reno Sub-Systems sales?
`
` A. Yes.
`
` Q. And were you in charge of all of
`
` Reno Sub-Systems marketing?
`
` A. Yes.
`
` Q. What was Reno Sub-Systems sales
`
` and marketing budget for 2021?
`
` A. I don't recall.
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`Page 24
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` Q. Do you have an estimate of what
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` Reno's marketing budget was for 2021?
`
` A. No.
`
` Q. Is there anyone at Reno
`
` Sub-Systems who would have that information?
`
` A. I can't be sure.
`
` Q. What about the sales and
`
` marketing budget at Reno for 2020, would you
`
` know that?
`
` A. No.
`
` Q. Is there any year that you
`
` worked at Reno which you recall the sales and
`
` marketing budget?
`
` A. Precisely, no.
`
` Q. It doesn't need to be precisely,
`
` Mr. Voltz. You can give me an estimate of the
`
` sales and marketing budget for any year you
`
` worked at Reno.
`
` MR. LESOVITZ: Objection to
`
` form.
`
` THE WITNESS: James, Reno was a
`
` very, very small company. Any budget
`
` that there was, was minuscule and aimed
`
` at paying our public relations company
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` to assist. We did no advertising. So
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` the budget was minimal at best.
`
` BY MR. MURPHY:
`
` Q. When you say "minimal at best,"
`
` do you have an estimate of what that would be?
`
` A. No, I don't.
`
` Q. Did you have a sales team?
`
` A. Yes.
`
` Q. You had to pay those people on
`
` your sales team I presume. Correct?
`
` A. Yes.
`
` Q. So are you including their
`
` compensation in your minimal budget?
`
` A. Yes.
`
` Q. To the best of your knowledge,
`
` was the sales and marketing budget for 2021
`
` above $1 million?
`
` MR. LESOVITZ: Objection. Calls
`
` for speculation.
`
` BY MR. MURPHY:
`
` Q. Mr. Voltz, just to be clear, if
`
` your attorney objects, you should still answer
`
` the question unless he instructs you not to.
`
` A. Repeat the question, please.
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`Exhibit 1027
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` Q. What were the primary products
`
` that Reno Sub-Systems would sell?
`
` A. Matching networks and RF
`
` generators.
`
` Q. Would Reno also sell gas flow
`
` systems?
`
` MR. LESOVITZ: Objection. Asked
`
` and answered.
`
` THE WITNESS: I'm sorry, Jeff, I
`
` didn't hear what you said.
`
` MR. LESOVITZ: I just made an
`
` objection asked and answered. You can
`
` answer if you can.
`
` THE WITNESS: Sometime during my
`
` tenure we sold the flow products
`
` division to another company.
`
` BY MR. MURPHY:
`
` Q. And prior to that, would Reno
`
` Sub-Systems sell gas flow systems?
`
` A. We offered them for sale.
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` Q. In terms of the RF matching
`
` networks, how many different products did you
`
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` have under that line of business?
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` MR. LESOVITZ: Objection to
`
` form.
`
` THE WITNESS: What do you mean
`
` by product?
`
` BY MR. MURPHY:
`
` Q. Did you have different models of
`
` RF match networks that Reno sold?
`
` A. Yes.
`
` Q. Do you recall how many different
`
` models that Reno would sell?
`
` A. Not exactly.
`
` Q. In terms of total revenue, how
`
` much came from the RF match networks compared
`
` to the RF generators?
`
` MR. LESOVITZ: Objection. Calls
`
` for speculation. It's also outside the
`
` scope of the declaration.
`
` BY MR. MURPHY:
`
` Q. Please answer the question, Mr.
`
` Voltz.
`
` A. For what period, James?
`
` Q. Let me rephrase it.
`
` For 2021, what was the percent
`
`Page 29
`
`Veritext Legal Solutions
`346-293-7000
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`9
`
`0
`
`1
`
`2
`
`3
`
`4
`
`n
`
` of total revenue generated by the RF match
`
` networks?
`
` MR. LESOVITZ: Objection. Calls
`
` for speculation.
`
`
`
`
`
`
`
`
`
` BY MR. MURPHY:
`
`
`
`
`
` Q. In your declaration, you
`
` referred to one product called the EVC
`
` velocity matching network. Do you recall
`
` that?
`
` A. Yes.
`
` Q. If I just refer to that as EVC
`
` Match as you do your network, is that okay?
`
` A. Yes.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Veritext Legal Solutions
`346-293-7000
`
`g
`
`Page 30
`
`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1027
`
`
`
`1
`
`2
`
`3
`
`4
`
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`6
`
`7
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`8
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`
`
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