UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ADVANCED ENERGY INDUSTRIES, INC.,
`Petitioner,
`vs. CASE IPR2021-01397
`PATENT 10,707,057
`
` RENO TECHNOLOGIES, INC.,
`
`Patent Owner.
`
` DEPOSITION OF: STEVEN C. SHANNON, Ph.D.
`CONFIDENTIAL - ATTORNEYS' EYES
`ONLY
`
` DATE:
`
`August 17, 2022
`
` TIME:
`
`9:09 a.m.
`
` LOCATION: Offices of
`BURLINGTON ENGINEERING LABS
`2500 Stinson Drive
`Raleigh, North Carolina
` TAKEN BY: Counsel for the Petitioner
` REPORTED BY: MINDY VISLAY (via VTC)
` ___________________________________________________
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`Veritext Legal Solutions
`346-293-7000
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`Page 1
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1029
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ADVANCED ENERGY INDUSTRIES, INC.,
`Petitioner,
`vs. CASE IPR2021-01397
`PATENT 10,707,057
`
` RENO TECHNOLOGIES, INC.,
`
`Patent Owner.
`
` DEPOSITION OF: STEVEN C. SHANNON, Ph.D.
`CONFIDENTIAL - ATTORNEYS' EYES
`ONLY
`
` DATE:
`
`August 17, 2022
`
` TIME:
`
`9:09 a.m.
`
` LOCATION: Offices of
`BURLINGTON ENGINEERING LABS
`2500 Stinson Drive
`Raleigh, North Carolina
` TAKEN BY: Counsel for the Petitioner
` REPORTED BY: MINDY VISLAY (via VTC)
` ___________________________________________________
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1029
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` APPEARANCES OF COUNSEL:
` ATTORNEYS FOR PETITIONER ADVANCED ENERGY
` INDUSTRIES, INC. (via VTC):
`
` POLSINELLI, P.C.,
` BY: JAMES P. MURPHY
` 1000 Louisiana Street
` Suite 6400
` Houston, Texas 77002
` 713-374-1600
` jpmurphy@polsinelli.com
`
` ATTORNEYS FOR THE PETITIONER ADVANCED ENERGY
` INDUSTRIES, INC. (via VTC):
`
` POLSINELLI, P.C.
` BY: GREG DURBIN
` 1000 Louisiana Street
` Suite 6400
` Houston, Texas 77002
` 713-374-1600
` gdurbin@polsinelli.com
`
` ATTORNEYS FOR PATENT OWNER
` RENO TECHNOLOGIES, INC. (via VTC):
`
` BAKER & HOSTETLER, LLP
` BY: JEFFREY W. LESOVITZ
` 1735 Market Street
` Suite 3300
` Philadelphia, Pennsylvania 19104
` 215-568-3100
` jlesovitz@bakerlaw.com
`
` ALSO PRESENT: Alan Walter (via VTC)
` Joseph Miller (via VTC)
` Anthony Martinez (via VTC)
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1029
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` STEVEN C. SHANNON, Ph.D.,
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` Being first duly sworn, testified as follows:
`
` DIRECT EXAMINATION
`
` BY MR. MURPHY:
`
` Q. Good morning, Dr. Shannon. Let me
`
` introduce myself. I'm James Murphy. I'm from
`
` Polsinelli. I represent the petitioner in this case
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` Advanced Energy. With me on this deposition is Greg
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` Durbin who is also from Polsinelli, and we also have a
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` representative of Advanced Energy Anthony Martinez
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` here.
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` And let me, you know, just remind you, the setup
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` for today's deposition, you know, we plan to discuss
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` nonconfidential information while Mr. Martinez is on
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` the phone. If you feel, you know, you need to reveal
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` any confidential information for an answer, let me
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` know, and we'll table that question until Mr. Martinez
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` leaves, and your attorney will also advise you if he
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` believes any answer requires confidential information.
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` It's certainly not my intent, but just try and keep in
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` mind not to reveal any confidential information until
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` later in the deposition after Mr. Martinez leaves.
`
` A. Okay.
`
` MR. MURPHY: And, Jeff, do you want to
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` introduce who's with you?
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` MR. LESOVITZ: Sure. Just before we do I
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` just want to make clear, Mr. Murphy, that if you do
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` intend to ask a question that may elicit confidential
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` information, it's obviously going to be up to you to
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` comply with the protective order, so we'd ask that you
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` advise Mr. Martinez that he would have to leave
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` before, you know, any questions are asked.
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` With that being said, I'll introduce myself. My
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` name is Jeff Lesovitz, and I represent Reno
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` Technologies, Incorporated, the patent owner, and with
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` me today is Mr. Alan Walter from Reno and Mr. Joseph
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` Miller, counsel for Reno Technologies.
`
` BY MR. MURPHY:
`
` Q. Okay. Dr. Shannon, you're aware you're
`
` here for the deposition -- or not deposition, sorry --
`
` the declaration you provided with respect to
`
` IPR2021-0139; is that right?
`
` A. Yes.
`
` Q. And that relates to U.S. Patent No.
`
` 10,707,057, correct?
`
` A. Yes.
`
` Q. Have you ever had your deposition taken
`
` before, Dr. Shannon?
`
` A. I have previously been deposed as a fact
`
` witness.
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`Exhibit 1029
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` Q. Was that relating to a patent case?
`
` A. Yes -- sorry. I'm sorry. It was a trade
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` secret case.
`
` Q. And what was the technology at issue there
`
` generally?
`
` A. Design of a dual frequency matching network
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` for semiconductor manufacturing applications.
`
` Q. And did you provide an expert report in
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` connection with that case?
`
` A. Pardon? Can you repeat that?
`
` Q. Yeah. Did you provide an expert report in
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` connection with that trade secret case?
`
` A. No. No. Only a deposition.
`
` Q. So let me just remind you. For the
`
` deposition today I'll be asking questions, and you
`
` provide the best answers that you can. Your attorney
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` may object, but you should still answer the question
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` to the extent you can. Do you understand that?
`
` A. Yes.
`
` Q. And do you understand that you're under
`
` oath today and your testimony has the same effect as
`
` if you were giving it directly before a judge?
`
` A. Yes.
`
` Q. And is there anything that would prevent
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` you from providing full and truthful answers today?
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` A. No.
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` Q. Did you review any documents to prepare for
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` your deposition today?
`
` A. I did.
`
` MR. LESOVITZ: I'm just going to -- I'm
`
` going to object that it's privileged, and you can
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` either answer that yes or no, Dr. Shannon.
`
` THE WITNESS: I did.
`
` BY MR. MURPHY:
`
` Q. Did you review the 057 patent to prepare
`
` for your deposition today?
`
` A. Yes.
`
` Q. Did you review the Mavretic reference to
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` prepare for your deposition today?
`
` A. Yes.
`
` Q. And did you review the Mason reference to
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` prepare for your deposition today?
`
` A. Yes.
`
` Q. Did you review the Navigator II reference
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` to prepare for your deposition today?
`
` A. That's the poster one, correct?
`
` Q. Correct.
`
` A. Yes.
`
` Q. And did you review your declaration when
`
` preparing for your deposition today?
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` A. Yes.
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` Q. And about how much time do you think you
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` spent reviewing documents to prepare for your
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` deposition today?
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` A. Approximately 50 hours.
`
` Q. And that's 5-0, correct?
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` A. Yes.
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` Q. And was that 50 hours just for today's
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` deposition, or are you including time you spent
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` preparing the declaration itself?
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` A. Both.
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` Q. So it's 50 hours both preparing your
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` declaration and preparing for today's deposition; is
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` that right?
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` A. Yes.
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` Q. And did you meet with any attorneys to help
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` you prepare for your deposition today?
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` A. Yes.
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` Q. Can you identify the attorneys you met
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` with?
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` A. Yes. Joe Miller and Jeffrey Lesovitz.
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` Q. And how long did you meet with Mr. Miller
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` and Mr. Lesovitz to prepare for today?
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` A. Approximately eight hours.
`
` Q. Okay. Dr. Shannon, let me add your
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1029
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` declaration -- the nonconfidential version -- to the
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` exhibit share.
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` A. Okay.
`
` Q. Let's see if you're able to access it. It
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` should be there now. You can look for it.
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` A. Do I have to hit refresh or anything to see
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` it? Okay. Yes. I see it.
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` Q. Okay. And can you open that exhibit?
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` (Court Reporter request for clarification
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` of the document.)
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` MR. MURPHY: It's been previously marked as
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` Exhibit 2017.
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` BY MR. MURPHY:
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` Q. And just to confirm that, Dr. Shannon, is
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` the document you're looking at, does it have Reno
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` Exhibit 2017 at the bottom?
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` A. Yes.
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` Q. And if you go to the last couple pages it
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` should say redacted, correct?
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` A. Yes.
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` Q. And does this document appear to be the
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` declaration that you submitted in the IPR proceeding?
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` A. It does.
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` Q. If you go to page 66, is that your
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` signature?
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`ADVANCED ENERGY INDUSTRIES INC.
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` A. One second. Page 66? One second. I lost
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` my scroll bar on the side of the window. There it is.
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` 66 you said?
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` Q. Yes.
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` A. Yes, that is my signature.
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` Q. When you signed the declaration you agreed
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` under penalty of perjury that all the statements in
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` there were true and correct as best as you know; is
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` that right?
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` A. Yes.
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` Q. And do you still agree that all the
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` statements in your declaration are true and correct?
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` A. Yes.
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` Q. As part of your declaration you discuss the
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` Mason reference, right?
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` A. Yes.
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` Q. I want to ask you some questions about the
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` Mason reference, so let me upload that to the exhibit
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` share.
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` Okay. It should be uploaded now, Dr. Shannon.
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` Let me know once you can access it.
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` A. Okay. So I need to close my declaration.
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` I can only look at one file at the time I take it?
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` Q. You should be able to have multiple files
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` open. You can also download them to your computer
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`ADVANCED ENERGY INDUSTRIES INC.
`Exhibit 1029
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` MR. LESOVITZ: Yeah, I think you have to
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` download them in order to see multiple exhibits at
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` once.
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` THE WITNESS: Got it. Yes. It's asking me
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` to download it as a zip file. Okay. I download it
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` from here. Sorry. Allow -- bear with me. I'm
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` bouncing around windows and everything here.
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` Okay. Now I'm at the Mason reference.
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` Download -- okay. So I have my declaration and the
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` Mason patent open.
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` BY MR. MURPHY:
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` Q. And the Mason patent was previously marked
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` as Exhibit 1005, and can you confirm that by looking
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` at the bottom of your document that it is labeled
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` Exhibit 1005?
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` A. Yes.
`
` Q. Turn to Figure 2 of the Mason reference.
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` A. Okay.
`
` Q. And do you agree that Figure 2 shows an
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` electronically variable capacitor?
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` A. Hang on. Apparently I need to get a free
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` seven-day trial to be able to rotate pages. Can you
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` repeat the question? I'm sorry.
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` Q. Yeah. Do you agree that Figure 2 of Mason
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` discloses an electronically variable capacitor?
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` A. Yes.
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` Q. If I refer to an electronically variable
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` capacitor as an EVC, is that okay?
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` A. Yes.
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` Q. What portion of Mason's Figure 2 is the
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` EVC?
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` A. I'm sorry. Will you repeat that?
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` Q. Yeah. What portion of Mason's Figure 2 is
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` the EVC?
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` A. So -- bear with me. Sorry. Are you asking
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` for my definition of an EVC or Mason's definition of
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` an EVC?
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` Q. Well, why don't we start with your
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` definition. What is your definition of an EVC?
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` A. My definition of an EVC is a capacitor
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` whose -- is a capacitor in a system whose impedance is
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` electrically actuated.
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` Q. And do you believe that's the meaning of
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` EVC as used in the 057 patent?
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` A. May I take a look at the 057 patent?
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` Q. Yeah. I will upload it to the exhibit
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` share for you.
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` Okay. Dr. Shannon, the 057 patent should be
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` available to you, and it's been previously marked as
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` MR. LESOVITZ: I'll just object for -- it's
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` calling for a legal conclusion and form.
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` THE WITNESS: Okay. One second. I
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` apologize for the interruption. I'm bouncing between
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` two parts of the 057 patent.
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` Okay. I'm sorry. Can you repeat the question?
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` BY MR. MURPHY:
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` Q. Is your understanding of an EVC the same as
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` the understanding of an EVC in the 057 patent?
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` MR. LESOVITZ: Same objections.
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` THE WITNESS: Can you repeat the question
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` one more time?
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` BY MR. MURPHY:
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` Q. Is your understanding of an EVC the same as
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` the understanding of an EVC in the 057 patent?
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` MR. LESOVITZ: Same objections.
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` THE WITNESS: I would include -- my
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` apologies. Repeat the question one more time.
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` BY MR. MURPHY:
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` Q. Is your understanding of an EVC the same as
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` the understanding of an EVC in the 057 patent?
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` MR. LESOVITZ: Same objections.
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` THE WITNESS: My understanding of an EVC
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` would be -- would fall under the definition of an EVC
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` BY MR. MURPHY:
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` Q. What do you mean by fall under? Do you
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` believe the meaning of an EVC in the 057 patent is
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` broader than your understanding of an EVC?
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` MR. LESOVITZ: Objection to form, misstates
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` testimony.
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` THE WITNESS: No, I do not think it's
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` broader.
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` BY MR. MURPHY:
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` Q. Okay. Let me ask it this way: How would a
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` person skilled in the art understand what an EVC means
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` in the 057 patent?
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` MR. LESOVITZ: Objection to form.
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` (Court Reporter request for clarification.)
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` MR. MURPHY: Yeah, am I cutting out again?
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` BY MR. MURPHY:
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` Q. Dr. Shannon, how would a person skilled in
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` the art have understood the meaning of EVC in the 057
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` patent?
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` A. So -- so the 057 patent defines an
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` electrically variable capacitor. It says -- sorry.
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` Let me rephrase that.
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` The 057 patent states that an electrically
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` variable capacitor includes a plurality of discrete
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` capacitors which formed an array and each discrete
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` capacitor has an electrode on opposite sides thereof
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` such is typical of discrete capacitors that are
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` available on the market.
`
` Q. Let's go back to Mason Figure 2,
`
` Dr. Shannon, and Figure 2 of Mason discloses an array
`
` of discrete capacitors, correct?
`
` A. Yes.
`
` Q. And the discrete capacitors are labeled as
`
` No. 208 in Figure 2; is that right?
`
` A. Yes.
`
` Q. And if you can turn to column 3, line 22 of
`
` Mason. It starts with the match 104. Let me know
`
` when you get there.
`
` A. Column 3 line what? I'm sorry.
`
` Q. 22.
`
` A. Okay. Match 104. Yes.
`
` Q. So in this sentence starting with the match
`
` 104 is it your opinion that there's a typo in this
`
` sentence?
`
` A. I do not see a typo in that sentence.
`
` Q. And this sentence discloses two or more
`
` variable capacitance elements, correct?
`
` A. This sentence includes two or more variable
`
` capacitance elements, yes.
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` sentence starting with in the alternative. Do you see
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` that? It's column 3 starting at line 25.
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` A. Yes.
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` Q. And in that sentence the variable
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` capacitive elements can be made from banks of parallel
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` electronically switched capacitors; is that right?
`
` A. Yes.
`
` Q. So would you agree that each electronically
`
` switched capacitor is an EVC?
`
` MR. LESOVITZ: Objection to form, misstates
`
` the document.
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` THE WITNESS: Can you repeat the question,
`
` please?
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` BY MR. MURPHY:
`
` Q. Yeah. Would you agree that each
`
` electronically switched capacitor is an EVC?
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` MR. LESOVITZ: Same objections.
`
` THE WITNESS: Can you repeat the question,
`
` please?
`
` BY MR. MURPHY:
`
` Q. Yeah. And I think I may have misstated it
`
` a little bit, so let me see if I can correct it.
`
` Do you agree that each variable capacitive element
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` is an EVC?
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` MR. LESOVITZ: Same objections.
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` THE WITNESS: Repeat that one more time for
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` me, please.
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` BY MR. MURPHY:
`
` Q. Do you agree that each variable capacitive
`
` element is an EVC?
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` MR. LESOVITZ: Same objections. It
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` misstates the document.
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` THE WITNESS: The definition of an EVC from
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` the 057 patent states that it includes a plurality of
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` discrete capacitors which formed an array and each
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` discrete capacitor as an electrode on the opposite
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` side thereof such as is typical of the discrete
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` capacitors that are available on the market. Does
`
` that answer your question?
`
` BY MR. MURPHY:
`
` Q. No, Dr. Shannon, it does not. I'm asking
`
` if the variable capacitative elements in Mason are an
`
` EVC.
`
` MR. LESOVITZ: Same objections.
`
` THE WITNESS: The definition of an EVC in
`
` the 057 patent refers to the assembly of discrete
`
` capacitors. If that assembly consisted of one
`
` discrete capacitor, then it would be the same
`
` definition.
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` BY MR. MURPHY:
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` Q. Do the variable capacitative elements in
`
` Mason only have one discrete capacitor?
`
` A. Can you repeat the question, please?
`
` Q. Yeah. Do the variable capacitative
`
` elements in Mason only have one discrete capacitor?
`
` A. Can you repeat the question, please?
`
` Q. Do the variable capacitative elements of
`
` Mason have only one discrete capacitor?
`
` A. Mason Figures 4 and 5 illustrate
`
` embodiments of the switched capacitor and switching
`
` circuit, and both of these embodiments only have one
`
` capacitor.
`
` Q. Those aren't embodiments of the variable
`
` capacitative element, are they?
`
` A. So the variable capacitative element in
`
` Mason comprises various switched capacitors coupled in
`
` parallel such as the switching in and out of each of
`
` the various switched capacitors alters the impedance
`
` to the variable capacitative element.
`
` So in the definition of variable capacitive
`
` element in Mason they define capacitors as plural, so
`
` the variable capacitive element under Mason would be
`
` defined as the assembly.
`
` Q. And Mason also discloses an RF generator,
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`Page 17
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`Exhibit 1029
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` correct?
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` A. Can you rephrase that?
`
` Q. Yeah. Mason also discloses an RF
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` generator, correct?
`
` A. So Mason states that a generator is what
`
` transmits RF power to a matching network.
`
` Q. Mason never describes that RF generator as
`
` a variable RF source, does he?
`
` A. Bear with me. Can you repeat the question?
`
` Q. Mason never describes the RF generator as a
`
` variable RF source, does he?
`
` A. Mason does reference variables that the
`
` plasma load or system load would depend on, and one of
`
` those variables that he mentions is generator
`
` frequency. It's the only mention of frequency that's
`
` made in the patent, but at several points he does
`
` discuss dependences on the frequency of the RF signal.
`
` Q. And are you referring to dependency of the
`
` plasma load as it relates to the RF frequency?
`
` A. That is one case where Mason discusses the
`
` dependency on the frequency of the RF signal.
`
` Q. And where is another case where Mason
`
` discusses the dependency?
`
` A. So, for example, column 6, line 11,
`
` "Depending on the frequency of the RF signal, the
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` voltage across the body capacitance of a transistor
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` will rise in one or more cycles."
`
` Q. And if you used a constant frequency
`
` source, the plasma load would still be dependent on
`
` the source of that constant frequency, right?
`
` MR. LESOVITZ: Objection to form.
`
` THE WITNESS: Can you repeat the question,
`
` please?
`
` BY MR. MURPHY:
`
` Q. If you used a constant RF source frequency,
`
` the plasma load would still depend on that constant
`
` source frequency, correct?
`
` A. The plasma load has a frequency dependence.
`
` Q. And that's true whether the RF source is
`
` variable or constant, correct?
`
` A. Yes.
`
` Q. Dr. Shannon, if you could turn to column
`
` 10, line 34 of Mason starting with Figure 6.
`
` A. Line what? Sorry.
`
` Q. 34.
`
` A. Yes. I see it. Okay. I'm on line 34.
`
` Q. And this paragraph describes Mason's method
`
` of tuning an impedance match network?
`
` A. So, according to Mason -- repeat the
`
` question. I'm sorry.
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` Q. This paragraph discloses Mason's method of
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` tuning an impedance match network, correct?
`
` MR. LESOVITZ: Objection to form.
`
` THE WITNESS: So that paragraph illustrates
`
` a method of tuning an impedance match network.
`
` BY MR. MURPHY:
`
` Q. And in the method illustrated there it
`
` involves switching a capacitor in or out of a variable
`
` capacitance element of match network, right?
`
` A. Yes.
`
` Q. And that would be consistent with tuning a
`
` match network using an EVC, correct?
`
` A. Can you repeat that? You got garbly on
`
` that.
`
` Q. Sorry about that. That would be consistent
`
` with tuning a match network using an EVC, correct?
`
` A. If it was electrically switched, yes.
`
` Q. And if the paragraph talks about switching
`
` a transistor to switch a capacitor in or out, that
`
` would be electrical switching, wouldn't it?
`
` A. I'm sorry. I jumped to the figure really
`
` quick. Can you direct me to the column and the line
`
` again?
`
` Q. Yeah. It's column 10, starting on line --
`
` A. 34?
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` Q. -- 34 for the paragraph, and particularly
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` the last sentence.
`
` A. So switching a transistor is an example
`
` that is given.
`
` Q. And that would be an electrical switch
`
` using the transistor; is that right?
`
` A. Yes.
`
` Q. Mason never describes a method of tuning an
`
` impedance match network using a variable frequency
`
` source, does he?
`
` MR. LESOVITZ: Objection to form.
`
` THE WITNESS: Can you repeat the question?
`
` BY MR. MURPHY:
`
` Q. Mason never describes a method of tuning an
`
` impedance match network using a variable frequency
`
` source, does he?
`
` A. Can you repeat the question, please?
`
` Q. Mason doesn't discuss a method of tuning an
`
` impedance match network using a variable frequency
`
` source, does he?
`
` A. No.
`
` Q. Mason doesn't discuss a method of tuning an
`
` impedance match network using a vacuum variable
`
` capacitor, does he?
`
` A. Mason mentions that vacuum variable
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` capacitors can be used.
`
` MR. LESOVITZ: Mr. Murphy, it looks like
`
` we've been going for over an hour now. Is now a good
`
` time to take a break?
`
` MR. MURPHY: Yeah. After a couple more
`
` questions. I don't think I got an answer to that last
`
` one, so let me re-ask it.
`
` THE WITNESS: Okay. Sorry.
`
` BY MR. MURPHY:
`
` Q. Does Mason disclose a method of tuning an
`
` impedance match network using a vacuum variable
`
` capacitor, Dr. Shannon?
`
` MR. LESOVITZ: Objection, asked and
`
` answered.
`
` THE WITNESS: Repeat the question, please.
`
` Sorry.
`
` BY MR. MURPHY:
`
` Q. Does Mason discuss a method of tuning an
`
` impedance match network using a vacuum variable
`
` capacitor?
`
` MR. LESOVITZ: Same objection.
`
` THE WITNESS: So Mason states that match
`
` networks can comprise a number of variable reactive
`
` elements. For instance, vacuum variable capacitors
`
` can be used.
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`Page 22
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`Exhibit 1029
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` BY MR. MURPHY:
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` Q. Does the method shown in Figure 6 of Mason
`
` apply to vacuum variable capacitors?
`
` A. You're going to make me turn my head
`
` sideways because I didn't get the seven-day.
`
` MR. LESOVITZ: Dr. Shannon, there should be
`
` a button that you can push to rotate the figure on the
`
` screen.
`
` THE WITNESS: There is, and it says I need
`
` to get a seven-day trial. The university has let its
`
` license on Adobe lapse because they're trying to
`
` package it into everything else, page maker and
`
` everything else, and so I'm stuck with the bare bones
`
` right now. So the university has deemed the health of
`
` my neck to be expendable in the interest of not paying
`
` for software.
`
` MR. LESOVITZ: If you look at it through
`
` the Zoom platform without downloading the document you
`
` should be able to rotate it that way as well.
`
` THE WITNESS: Oh. All right. It's okay.
`
` I can do it.
`
` MR. LESOVITZ: I just want to make sure you
`
` don't strain your neck too much.
`
` THE WITNESS: I appreciate your concern,
`
` thank you, but if it starts bothering me I'll switch
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` for sure.
`
` Can you repeat the question? I'm sorry.
`
` MR. MURPHY: Yeah. Can the court reporter
`
` repeat the question?
`
` (WHEREIN, the requested portion of the
`
` record was read by the court reporter.)
`
` THE WITNESS: Figure 6 does not define what
`
` kind of capacitor it needs to be just that a capacitor
`
` is part of the decision tree.
`
` BY MR. MURPHY:
`
` Q. Does a vacuum variable capacitor utilize a
`
` transistor?
`
` A. A vacuum variable capacitor is simply a
`
` capacitor.
`
` Q. This method turns on and off a transistor,
`
` correct?
`
` A. Yes.
`
` Q. If you were tuning a vacuum variable
`
` capacitor would you turn on or off the transistor?
`
` A. You could.
`
` Q. This method also requires biasing a diode,
`
` correct?
`
` (Court Reporter request for clarification.)
`
` THE WITNESS: Yes.
`
` MR. MURPHY: B-I-A-S-I-N-G a diode.
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` BY MR. MURPHY:
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` Q. I'm sorry. I think you answered,
`
` Dr. Shannon. I talked over you.
`
` A. Sorry. You're okay. Yes.
`
` Q. What was your answer?
`
` A. Yes.
`
` Q. Would a vacuum variable capacitor bias a
`
` diode?
`
` A. Can you repeat the question one more time?
`
` MR. MURPHY: Can the court reporter repeat
`
` the question?
`
` (WHEREIN, the requested portion of the
`
` record was read by the court reporter.)
`
` THE WITNESS: I don't understand the
`
` question. I'm sorry.
`
` BY MR. MURPHY:
`
` Q. Well, the method here requires biasing the
`
` first diode, correct? The method in Figure 6.
`
` A. Yes.
`
` Q. If you were using vacuum variable
`
` capacitors to tune an impedance matching network would
`
` you bias a diode?
`
` A. Using the diagram of Figure 6 you could.
`
` Q. And what would be the purpose of biasing a
`
` diode in relation to a vacuum variable capacitor?
`
`Page 25
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`Exhibit 1029
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` A. To switch the impedance of the circuit
`
` element that contains the vacuum variable capacitor.
`
` Q. So you're suggesting you would completely
`
` switch in or out a vacuum variable capacitor?
`
` MR. LESOVITZ: Objection to form.
`
` THE WITNESS: Figure 6 does not suggest you
`
` couldn't.
`
` BY MR. MURPHY:
`
` Q. I'm asking you for your opinion,
`
` Dr. Shannon. Are you suggesting that one with skill
`
` in the art would completely switch in or out a vacuum
`
` variable capacitor?
`
` MR. LESOVITZ: Same objection.
`
` THE WITNESS: You could, yes.
`
` MR. MURPHY: Why don't we take a break
`
` there, then.
`
` (A short recess was taken.)
`
` BY MR. MURPHY:
`
` Q. Welcome back, Dr. Shannon.
`
` A. Thank you.
`
` Q. Let's turn back to Figure 6 of Mason which
`
` we were looking at before the break.
`
` A. Yes.
`
` Q. So the method in Figure 6 also requires
`
` reducing or increasing current in the switched
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` capacitor, correct?
`
` A. Yes.
`
` Q. A vacuum variable capacitor does not
`
` contain a switched capacitor, does it?
`
` A. Can you define switched capacitor for me?
`
` Q. So are you aware of what Mason describes as
`
` a switched capacitor?
`
` A. So I'm seeing switched capacitor as what's
`
` referenced as element 208 in Figure 2. Is that an
`
` accurate interpretation?
`
` Q. That's your understanding of a switched
`
` capacitor in the context of Mason?
`
` MR. LESOVITZ: Objection to form.
`
` THE WITNESS: Can you repeat the question,
`
` please?
`
` BY MR. MURPHY:
`
` Q. What is your understanding o
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