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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ___________________
`
` BEFORE THE PATENT AND APPEAL BOARD
`
` ___________________
`
` APPLE INC.,
`
` Petitioner,
`
` v.
`
` SCRAMOGE TECHNOLOGY LTD.,
`
` Patent Owner.
`
` __________________
`
` Case IPR2022-00117
`
` U.S. Patent No. 9,843,215
`
` REMOTE DEPOSITION OF
`
` JOSHUA PHINNEY, Ph.D., P.E.
`
` Thursday, July 21, 2022
`
` 9:57 a.m. Pacific Time
`
`Stenographically Reported By:
`
`Lorie Rhyne, CSR No. 12905
`
`Job No. 5270
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Scramoge Technology Ltd.
`Ex. 2018 - Page 1
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ___________________
`
` BEFORE THE PATENT AND APPEAL BOARD
`
` ___________________
`
` APPLE INC.,
`
` Petitioner,
`
` v.
`
` SCRAMOGE TECHNOLOGY LTD.,
`
` Patent Owner.
`
` __________________
`
` Case IPR2022-00117
`
` U.S. Patent No. 9,843,215
`
` REMOTE DEPOSITION OF
`
` JOSHUA PHINNEY, Ph.D., P.E.
`
` Thursday, July 21, 2022
`
` 9:57 a.m. Pacific Time
`
`Stenographically Reported By:
`
`Lorie Rhyne, CSR No. 12905
`
`Job No. 5270
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Scramoge Technology Ltd.
`Ex. 2018 - Page 1
`
`
`
`Page 2
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`DEPOSITION OF: JOSHUA PHINNEY, Ph.D., P.E.
`
`DATE: Thursday, July 21, 2022
`
`TIME: 9:57 a.m. Pacific Time
`
`LOCATION: Conducted remotely with all
`
` parties appearing via Zoom
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`
`
` APPEARANCES:
`
`Page 3
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` APPEARING FOR PETITIONER:
`
` SCOTT JARRATT, ESQ.
`
` CALMANN J. CLEMENTS, ESQ.
`
` Haynes Boone, LLP
`
` 6000 Headquarters Drive, Suite 200
`
` Plano, Texas 75024
`
`(972) 739-8663
`
` scott.jarratt@haynesboone.com
`
` calmann.clements@haynesboone.com
`
` APPEARING FOR PATENT OWNER:
`
` JOHN PETRSORIC, ESQ.
`
` Russ August & Kabat
`
` 12424 Wilshire Boulevard, 12th Floor
`
` Los Angeles, California 90025
`
`(310) 826-7474
`
`jpetrsoric@raklaw.com
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`
`
` I N D E X
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`Page 4
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` EXAMINATION
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` WITNESS:
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` Joshua Phinney
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` Mr. Petrsoric
`
` 5
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` EXHIBIT(S) REFERENCED
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` EXHIBIT
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` PAGE
`
` Exhibit 1003 Declaration of Dr.
`
` Joshua Phinney
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`
`
` Conducted Remotely
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` 9:57 a.m. Pacific Time
`
`Page 5
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` JOSHUA W. PHINNEY, Ph.D., P.E.,
`
` having first been duly sworn, was examined and
`
` testified as follows:
`
` EXAMINATION
`
` BY MR. PETRSORIC:
`
` Q. Good morning, Dr. Phinney.
`
` A. Good morning.
`
` Q. Do you have in front of you the declaration
`
` you submitted in the IPR proceeding, or the
`
` inter partes review proceeding, IPR2022-00117?
`
` A. Yes.
`
` Q. Is it okay if we refer to this IPR
`
` proceeding as the "117 proceeding"?
`
` A. Yes, that's -- that's okay. I'll be a
`
` little bit slow with that nomenclature, so you may have
`
` to remind me because, because -- but I'll try.
`
` Q. I don't think it'll come up, but just in
`
` case.
`
` This declaration relates to U.S. Patent
`
` Number 9,843,215; correct?
`
` A. Yes.
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` Q. Do you also have a copy of that patent in
`
`Page 6
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` front of you?
`
` A. I do.
`
` Q. Is it okay if we refer to this patent as the
`
` "'215 patent"?
`
` A. Agreed.
`
` Q. Your declaration was submitted as
`
` Exhibit 1003 in the 117 IPR proceeding; correct?
`
` A. Yes.
`
` Q. Do you have a copy of U.S. Patent 6,948 --
`
` sorry -- 9,443,648 to Sawa available?
`
` A. Yes.
`
` Q. How did you prepare for your deposition
`
` today?
`
` A. I met with counsel and reviewed my
`
` declaration.
`
` Q. And how long, approximately, did you meet
`
` with counsel for?
`
` A. Approximately six to eight hours.
`
` Q. And was that preparation -- in preparation
`
` solely for this deposition or deposition in other
`
` proceedings?
`
` A. It was -- I'm trying not to count time --
`
` one of the meetings had -- was mixed, and that included
`
` multiple IPR proceedings.
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`Page 7
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` Q. Besides meeting with counsel and reviewing
`
` your declaration, did you do anything else to prepare
`
` for your deposition today?
`
` A. Just looking at the references cited in my
`
` declaration as part of reviewing.
`
` Q. A minute ago, I mentioned the '648 patent,
`
` which is to Sawa. Did you review that patent in
`
` preparation for your deposition today?
`
` A. Yes.
`
` Q. And is it okay if we refer to that
`
` '648 patent as the "Sawa" reference?
`
` A. Yes.
`
` Q. Or do you prefer something else?
`
` A. Sawa is -- is my preferred way.
`
` Q. Do you have a -- a recollection of
`
` approximately how long you spent preparing the
`
` declaration you submitted in this 117 proceeding?
`
` A. Yes. It's -- it's somewhat vague, but back
`
` in September, approximately, of 2022.
`
` Q. And -- and do you -- do you have any
`
` recollection as to how much time you spent preparing --
`
` reviewing the prior art and preparing the declaration?
`
` A. I'd say it would be around two to
`
` three days.
`
` Q. Did you write the initial draft of the
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`Page 8
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` declaration yourself?
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` A. Parts of it. Others, I didn't draft in the
`
` first instance, but it -- it reflects my opinions.
`
` Q. Do you -- do you recall what parts you
`
` didn't draft in the first instance?
`
` A. There could be some parts with the -- just
`
` the -- the -- the claim analysis as applied to
`
` particular claim elements. That's something I
`
` discussed with counsel, but what's in the declaration
`
` are -- are my opinions.
`
` Q. How many times have you been deposed before?
`
` A. It's somewhere in the upper 30s, probably
`
` not 40 yet.
`
` Q. So you're fairly -- you're familiar with the
`
` ground rules?
`
` A. I -- I'd say so.
`
` Q. And given the -- the excessive heat today,
`
` if you need to take a break, please let me know. All
`
` I'll ask is that you just allow me to finish a line of
`
` questioning, and we'll get through that as quickly as
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` possible, if that's okay?
`
` A. Thank you. Yes.
`
` Q. And I -- I would urge you to take your
`
` jacket off as well, but I don't want to step on your
`
` attorney's toes. It's not on video.
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`
`
` Paragraph 9 of your declaration is on
`
` page 6. Could you turn to that?
`
` A. Okay. I'm there.
`
` Q. And this describes the work you did for your
`
`Page 9
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` master's thesis at MIT; correct?
`
` A. Yes.
`
` Q. And can you describe that work in more
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` detail?
`
` A. Yes. I was concerned with magnetics designs
`
` and how certain circuit and control techniques could be
`
` used to decrease the volume of the magnetics designs
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` for the same performance. So I could delve into
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` different areas of that, if you'd like.
`
` Q. I'll just quickly -- I'll just ask one
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` follow-up.
`
` When you say "decrease the volume," you mean
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` the -- the -- the size of an -- of an electronic
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` component?
`
` A. Yes.
`
` Q. And -- and in doing that work, did you have
`
` to choose compositions or the material compositions of
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` the magnetic devices you were working with?
`
` A. Yes.
`
` Q. Did you have to investigate the
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` character- -- the magnetic characteristic of those
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` devices and compositions?
`
` A. Yes.
`
` MR. JARRATT: Objection. Scope.
`
` BY MR. PETRSORIC:
`
` Q. Did you do any testing of those compositions
`
` for magnetic properties?
`
` A. Yes.
`
` MR. JARRATT: Objection. Scope.
`
` BY MR. PETRSORIC:
`
` Q. And -- and what type of testing of -- did
`
` you do for those magnetic properties?
`
` MR. JARRATT: Objection. Scope.
`
` THE WITNESS: The kinds of things I was
`
` concerned with were ultimately about loss and coming up
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` with a -- what's often a very hard to quantify metric
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` for how lossy a particular component will be. But you,
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` at the same time, want to compare, potentially,
`
` millions of designs and -- but you don't want to build
`
` them all, but you'd like to predict their loss.
`
` So that was a combination of measurements
`
` and empirical approach, but also some modeling, all in
`
` an attempt to make a -- an inductor with a particular
`
` loss characteristic.
`
` BY MR. PETRSORIC:
`
` Q. And when you say "loss characteristic," is
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` that more of a magnetic property or an electrical
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` property?
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` A. Well, it has a very strong magnetic
`
` component to it called the "core loss." And the core
`
` loss is a -- is a magnetic property, and that's
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` actually the one that's hard to predict. And I adopted
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` a more empirical approach compared to other types of
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` ohmic loss due to the -- the windings.
`
` Q. And since that thesis work, did you -- have
`
` you done any other modeling of magnetic properties or
`
` simulation -- modeling simulations or predictions for
`
` magnetic properties?
`
` MR. JARRATT: Objection. Scope.
`
` THE WITNESS: Yes.
`
` BY MR. PETRSORIC:
`
` Q. And was that in the context of obtaining
`
` your doctorate?
`
` A. Yes, some of it was.
`
` Q. And -- and did you do any modeling work or
`
` testing work in conjunction with your declaration that
`
` you submitted in the 117 proceeding?
`
` A. No, I didn't do testing.
`
` Q. Did you do any modeling work?
`
` A. No, I also didn't -- didn't model in the
`
` sense of -- that I was talking about with the master's
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`Page 12
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` in terms of circuits and waveforms.
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` Q. If we turn to page 31 of your declaration,
`
` and this deals with what you've identified as
`
` limitation or Element 1.1 of the '215 patent, which is
`
` a plurality of soft magnetic layers comprising a first
`
` soft magnetic layer and a second soft magnetic layer.
`
` Do you see that?
`
` A. Yes.
`
` Q. The first sentence is -- in the first
`
` sentence you say, Sawa's device has a magnetic sheet 1
`
` that includes a plurality of magnetic plates, and then
`
` in parentheses ("soft magnetic layers").
`
` Do you see that?
`
` A. Yes.
`
` Q. So are you alluding or concluding that the
`
` magnetic plates in Sawa are all soft magnetic plates?
`
` A. They -- they -- they generally are. As I'm
`
` providing this -- you know, these -- these block quotes
`
` that are describing some of the materials and, yes,
`
` indeed, like, you know, the permalloy or silicon steel
`
` and others -- and these are real classic, soft magnetic
`
` materials that can be used to form the -- the different
`
` plates.
`
` Q. And -- and if you look down in the -- in
`
` paragraph 59 further there, you've -- you've got a
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`
`
` citation from column 4, lines 5 to 29 of Sawa.
`
` Do you see that? And -- and that goes from
`
`Page 13
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` page 31 into page 32.
`
` A. Yes, I see that.
`
` Q. You've got a couple of things highlighted,
`
` and I'm going to skip the first two. And you say, A
`
` first mag- -- you highlight, A first magnetic thin
`
` plate.
`
` And what I understand you -- you to be
`
` telling me is that you -- you understand that first
`
` magnetic plate in Sawa to be a soft magnetic material?
`
` A. It -- it certainly would be obvious that it
`
` could be a -- a soft magnetic material. That would be
`
` in -- in keeping with its role in Sawa.
`
` Q. And then the same -- same question for the
`
` second magnetic thin plate. Would that -- would you
`
` understand that second magnetic thin plate to be a soft
`
` magnetic material in Sawa?
`
` A. Yes, it -- it certainly can be. It would
`
` be, for instance, obvious to a person of ordinary skill
`
` that it -- that it is a -- a soft magnetic material, or
`
` can be.
`
` Q. And then in -- right after, A second
`
` magnetic thin plate, it says, Different in kind from
`
` the first magnetic thin plate.
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`Page 14
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` Did you see that?
`
` A. Yes.
`
` Q. Do you have any understanding of what Sawa
`
` is referring to when the specification says the second
`
` magnetic thin plate is different in kind from the first
`
` magnetic thin plate?
`
` A. Yes.
`
` Q. And -- and what is that understanding?
`
` A. I think that's alluded to right here in this
`
` quote. So the first thin plate, which was that -- was
`
` called numeral 2. So there's going to be,
`
` unfortunately, a lot of numbers here.
`
` Q. I've -- I've been through Sawa enough so
`
` I'm -- I -- I appreciate what you were going to say.
`
` A. Yes. And it comes down to what it says
`
` here, that the magnetic plate 2 -- I'm reading here in
`
` that block quote after that last highlighted portion
`
` that you wrote -- you -- you pointed out that read
`
` about the second magnetic thin plate.
`
` So the first magnetic thin plate is a
`
` magnetic thin plate which is hard to be
`
` magnetic-saturated even if a magnet exists in the -- my
`
` page just shifted.
`
` Q. That's okay. Take -- take your time. No
`
` rush today. I don't -- I don't think we're going all
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`Page 15
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` afternoon.
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` A. Okay. Would you mind just quickly tell me
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` what page that was we were reading on again? Sorry.
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` Q. Page 31 of the declaration.
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` A. Okay. Thank you. Sorry. It just --
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` Q. No, that's okay.
`
` A. Okay. So that's -- that's an example is
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` that that magnetic thin plate is hard to be
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` magnetic-saturated even if there is a magnet in the
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` power-feeding device site.
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` Q. Okay. What is -- what does it mean to be
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` hard to be magnetic-saturated?
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` A. Well, you know, if you have a -- if you have
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` a magnet for alignment purposes that's on the -- the
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` transmitter side, that could be something that's --
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` that's for alignment. Sometimes these -- these
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` wireless charging systems have a magnet that's designed
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` to sort of bring the coils into axial alignment.
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` And one sort of down side of that is, is
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` that a large DC magnetic field can cause a magnetic
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` material to be pushed up its so-called B-H curve, which
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` represents the response of the material to an
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` externally applied magnetic field.
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` And the problem is all of the power
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` transmission properties of this system depend on AC --
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`Page 16
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` so not the DC bias, but the -- the way that you're
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` wiggling around that DC bias point. And if you imagine
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` biasing the magnetic material to a point where all of
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` its internal magnetic states simply align with the
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` magnetic field, they're sort of pinned in that
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` direction by the DC magnetic field and they don't have
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` any latitude to actually shift or move as part of the
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` power transfer process.
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` And what we say is they're saturated because
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` they -- it's just the material has given all it can
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` give and it's all aligned with the external magnetic
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` field. And that will actually prevent, you know, the
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` guiding of AC flux in the desired manner if you
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` saturate that material.
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` So you -- you're kind of aware of this
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` problem and you choose a material that can avoid the
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` saturation problem in that one layer that could be
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` close to the magnet that causes the problem.
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` Q. Okay. So -- let me ask you a basic
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` question. When -- when you've got a magnetic material
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` and it doesn't have soft magnetic properties, does it
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` have hard magnetic properties, or is it considered to
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` have hard magnetic properties?
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` A. It's -- it's -- it's a -- it's a somewhat
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` arbitrary distinction because there's a continuum of a
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`Ex. 2018 - Page 16
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`
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` particular property, it's called the coercivity, and so
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` there's many normal core materials that are simply
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` there to guide flux -- are intended to be soft magnetic
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`Page 17
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` materials with low coercivity, and the more that
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` they're there to simply guide flux in a power
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` conversion process, you want them to have low
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` coercivity in order to decrease their core loss.
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` So, hence, the -- the -- the permalloys and
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` amorphous alloys and, you know, there's -- there's --
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` there's many choices that have -- are designed to have
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` low coercivity, yet have high permeability as -- at the
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` desired frequency.
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` Q. And -- and would -- would any hard magnetic
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` material also satisfy those design criteria?
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` A. They could potentially guide flux in some
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` way, but, you know, this -- this description in Sawa is
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` describing, essentially, permanent magnets or the hard
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` magnetic materials as being -- introducing sort of a
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` problem that the more flux-guiding structures and --
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` which include some soft magnetic materials -- or at
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` least that's one option for building -- they have to
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` sort of cope with that problem posed by a hard magnetic
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` material like a -- like a permanent magnet that might
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` be there for purposes of alignment.
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` Q. Would a hard magnetic material necessarily
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`Page 18
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` be a permanent magnet?
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` A. Again, it's a continuum a little bit. It
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` doesn't have to be, but -- but that's -- that's --
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` that's -- that's a -- a typical type of material.
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` It -- it has -- it has a very -- it has high coercivity
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` and it takes a high external applied magnetic field in
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` order to align the internal magnetic states in a
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` desired direction, and there will typically be a large
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` remnant magnetization as a result of that extreme
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` hysteresis in the material.
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` And that -- that remnant magnetization is
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` something that we -- we see in experience usually is
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` like the permanent -- a permanent magnet. You know,
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` that's -- it -- it like has that magnetic moment even
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` after the external magnetic field has been taken away.
`
` Q. You mentioned high coercivity. A moment
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` ago, you had mentioned soft with low coercivity, and I
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` think you were referring to that for the first plate of
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` Sawa, if I'm not mistaken.
`
` Did I miss something?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: I guess I'm not quite sure
`
` what you're asking. I was talking about soft magnetic
`
` materials and how they have generally low coercivity.
`
` BY MR. PETRSORIC:
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`Page 19
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` Q. So -- okay. That -- now, I understand
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` that -- I had it backwards, so just make sure I
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` understand something.
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` So what Sawa is -- from your understanding
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` is teaching is that the first plate had -- is the soft
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` magnetic layer with higher coercivity?
`
` MR. JARRATT: Objection. Form.
`
` THE WITNESS: I'm -- I'm saying that the
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` first magnetic material is -- is -- first of all, Sawa
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` lists materials and -- and other things that make it
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` clear that soft magnetic materials are certainly a
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` choice for any of its magnetic plates.
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` But what I'm saying with the -- this
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` particular property of that first magnetic thin plate
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` is that it is difficult for it to be saturated. And
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` that -- that being a key performance criteria, and
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` that's -- that's mentioned in Sawa because it may have
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` to cope with the presence of an external applied DC
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` magnetic field.
`
` BY MR. PETRSORIC:
`
` Q. So then you would -- would -- I understand
`
` you're saying is that Sawa would want that first
`
` magnetic thin plate to have sufficient coercivity such
`
` that it wouldn't be saturated by the presence of the
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` permanent magnet?
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` MR. JARRATT: Objection. Form.
`
` THE WITNESS: No, that's -- that's not what
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` I'm -- I'm saying. I'm just -- I'm just indicating
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` that it is designed with an eye to being far enough
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` away from saturation through whatever means that it
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` won't be saturated in normal use. And so that --
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` that's actually disjoint in some ways from coercivity.
`
` BY MR. PETRSORIC:
`
` Q. Okay, got it.
`
` I -- I -- so I'm understanding that
`
` coercivity does not have a direct relationship with
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` preventing saturation?
`
` A. I'd say that's true. It's -- it's more
`
` about how far up a curve you are operating because at
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` the end of that curve is a saturation point. And so
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` you don't want to operate the material or what's called
`
` bias the material in a way that's so close to the edge
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` or actually already saturated that the whole flux -- AC
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` flux guiding properties of the material are
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` compromised.
`
` Q. If -- if you look at -- just look at Sawa at
`
` the bottom of column 2 from line 56 to the top of
`
` column 3, line 8. Sawa mentions that A conventional
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` magnetic shield has a magnetic thin plate with a
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` saturation magnetic flux density of 0.55 to 2T or 5 --
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`Page 21
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` (5.5 to 20 kilograms).
`
` Do you see that?
`
` A. Yes.
`
` Q. At -- at -- what does -- can you explain to
`
` me what that's teaching?
`
` A. So that -- it's using these two units of
`
` tesla, which is -- one tesla is about 10 -4 gauss. So
`
` for kilogauss, you kind of shift the -- the -- you
`
` shift the decimal point, and it's -- it's in these two
`
` units, gauss and tesla, it's telling you at what
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` point -- at what magnetic flux density the -- the
`
` conventional magnetic shield can be saturated.
`
` Q. Okay. If you look down in the next
`
` paragraph beginning at line 65, it says, Since a
`
` magnetic thin plate used in the conventional magnetic
`
` shield is excellent in soft magnetic characteristic,
`
` use of a laminated range of 1 or 3 or less magnetic
`
` thin plates with a saturation magnetic flux density of
`
` 0.5 to 2 tesla causes magnetic saturation easily if a
`
` magnet exists in the neighborhood.
`
` Do you see that?
`
` A. Yes.
`
` Q. So that -- I -- I understand what -- what
`
` Sawa is describing there is the problem that you've
`
` alluded to is that there -- that certain soft magnetic
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`Ex. 2018 - Page 21
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`
`Page 22
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` materials are -- would be too easily saturated in the
`
` presence of a permanent magnet?
`
` A. Yes, that's -- that's a -- that's a
`
` potential danger.
`
` Q. And then so -- I under- -- am I correct in
`
` understanding that Sawa sought -- sought to overcome
`
` that potential danger?
`
` A. That's -- some of the embodiments in Sawa,
`
` yes, are directed to -- to choosing magnetic layers or
`
` treating them in such a way that they -- they can
`
` counteract or mitigate that problem.
`
` Q. Turning back to your declaration,
`
` paragraph 60 on page 32.
`
` A. Okay, I'm there.
`
` Q. Okay. Paragraph 60 also runs to page 33 and
`
` the -- or actually, to, I believe, the page 34. And
`
` there's a first citation from column 8, line 59 to
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` column 9, line 11 of Sawa specification.
`
` Do you see that?
`
` A. Yes.
`
` Q. You've highlighted one sentence that
`
` straddles pages 32 and 33, and it reads, The composing
`
` material of the first magnetic thin plates 2 there can
`
` be cited an Fe alloy of an Fe-Cr system, an Fe-Ni
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` system, an Fe-Si system, or the like.
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`Page 23
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` And can you tell me why you were
`
` highlighting that particular sentence?
`
` A. Well, the -- just because in that -- in that
`
` group are sort of famous soft magnetic materials
`
` commonly used in like the nickel -- nickel-iron system.
`
` That can include things like permalloy, a nickel-rich
`
` kind of alloy, very high permeability, quite soft, soft
`
` magnetically, it has low hysteresis. So it's just a
`
` wonderful core material.
`
` And then -- then historically, silicon iron
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` is another one. This is -- again, this is -- silicon
`
` is used in transformer materials and cores to do things
`
` like lower the coercivity. You -- you can actually --
`
` if you have, like, native steel, you can add in a
`
` silicon -- with a silicon solution, you can essentially
`
` decrease coercivity, decrease core loss -- and this
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` is -- those -- those -- that's because you made the
`
` material more magnetically soft. It has more -- it has
`
` less coercivity and less core loss.
`
` And that's why it's been used so commonly
`
` in, for instance, power system transformers. It's
`
` sometimes called transformer steel.
`
` Q. And the -- the first system was Fe-Cr.
`
` That's -- Cr is chromium; correct?
`
` A. Yes.
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`Page 24
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` Q. So that's -- that sounds like a
`
` stainless steel system?
`
` A. Yes. Yeah, I'm looking here. I think that
`
` could include Kovar, I think, is in the chromium -- has
`
` chromium in it.
`
` Q. Okay. And then right after Kovar, the next
`
` sentence states, The first magnetic thin plate 2 is
`
` preferable to be made of the stainless steel among the
`
` above and -- of a ferrite system, stainless steel in
`
` particular.
`
` So I -- I gather Sawa was saying but for the
`
` first magnetic thin plate, stainless steel was the
`
` preferable material?
`
` A. It -- I could -- it could be saying that
`
` with that one clause, but then it's got this -- this
`
` latter part of the sentence, it says, of a ferrite
`
` system, stainless steel in particular.
`
` Q. Do you know what a ferrite system,
`
` stainless steel in par- -- might be referring to in
`
` particular?
`
` A. It -- it -- I think it's something that is
`
` different than merely iron-chromium kind of
`
` composition, not just merely an alloy like you think
`
` of, like, metallic alloy. So, in particular, I think
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` it just would have other elements, some other
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`Page 25
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` composition in it beyond iron and chromium.
`
` Q. The following recitation from the
`
` specification of Sawa, which is from column 11,
`
` lines 12 to 45, this is -- straddles pages 33 to 34 of
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` the declaration. This is with regards to the second
`
` magnetic thin plate in Sawa; correct?
`
` A. Yes.
`
` Q. And I think you highlighted the Si in the
`
` general formula 1 to show that there's silicon in that
`
` particular composition?
`
` A. Correct.
`
` Q. On page 34, you highlighted Si (silicon) and
`
` B (boron) are elements effective for amorphousing a
`
` magnetic alloy.
`
` Do you see that?
`
` A. Yes.
`
` Q. Can you explain to me what amorphousing a
`
` magnetic alloy is?
`
` A. Sure. You may be -- frequently in -- in
`
` chemistry, people learn about the difference between a
`
` quartz, which is more of a crystal versus glass, which
`
` can be sort of an amorphous version of the solid. And,
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` you know, what a chemistry textbook will point out is
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` like, well, both have the same composition, SiO2. But
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` what differs about them is long-range order.
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`Page 26
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` So, whereas the quartz has a more
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` crystalline structure, there's more disorder at a
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` microscopic level, at an atomic level, really, in the
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` glass. And so it's -- it's that type of situation
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` where instead of crystalline grains because of the
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` rapid clenching that you see in some of these amorphous
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` materials, there's silicon as one particular example
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` kind of -- you know, getting in and -- and disrupting
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` the otherwise orderly crystal arrangeme
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