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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ********************************
` MEDIVIS, INC.,
` Petitioner,
`
` v.
`
` NOVARAD CORP.,
` Patent Owner.
` Inter Partes Review No. IPR2023-00042
` US Patent No. 11,004,271
`
` Inter Partes Review No. IPR2023-00045
` US Patent No. 10,945,807
` *********************************
`
` Remote Deposition of MAHESH S.
`MULUMUDI, MD, held at the location of the
`deponent, commencing at 10:06 a.m. Eastern, on
`the 19th of September, 2023, before Maureen
`O'Connor Pollard, Registered Diplomate Reporter,
`Realtime Systems Administrator, Certified
`Shorthand Reporter, Notary Public.
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`1-800-727-6396
`
`Veritext Legal Solutions
`
`www.veritext.com
`
`Medivis Exhibit 1022
`
`1
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ********************************
` MEDIVIS, INC.,
` Petitioner,
`
` v.
`
` NOVARAD CORP.,
` Patent Owner.
` Inter Partes Review No. IPR2023-00042
` US Patent No. 11,004,271
`
` Inter Partes Review No. IPR2023-00045
` US Patent No. 10,945,807
` *********************************
`
` Remote Deposition of MAHESH S.
`MULUMUDI, MD, held at the location of the
`deponent, commencing at 10:06 a.m. Eastern, on
`the 19th of September, 2023, before Maureen
`O'Connor Pollard, Registered Diplomate Reporter,
`Realtime Systems Administrator, Certified
`Shorthand Reporter, Notary Public.
`
` – – –
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`1-800-727-6396
`
`Veritext Legal Solutions
`
`www.veritext.com
`
`Medivis Exhibit 1022
`
`1
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`
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`Page 2
`
`REMOTE APPEARANCES:
`McCARTER & ENGLISH, LLP
`BY: KIA L. FREEMAN, ESQ.
`BY: LEAH R. McCOY, ESQ.
` 265 Franklin Street
` Boston, Massachusetts 02110
` 617-449-6593
` kfreeman@mccarter.com
` lmccoy@mccarter.com
` Representing the Petitioner, Medivis, Inc.
`THORPE, NORTH & WESTERN LLP
`BY: JOSEPH HARMER, ESQ.
` The Walker Center
` 175 S. Main Street
` Salt Lake City, Utah 84111
` joseph.harmer@tnw.com
` Representing the Patent Owner,
` Novarad Corp.
`THORPE, NORTH & WESTERN LLP
`BY: JED H. HANSEN, ESQ.
` 8180 South 700 East, Suite 350
` Sandy, Utah 84070
` hansen@tnw.com
` Representing the Patent Owner,
` Novarad Corp.
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`Medivis Exhibit 1022
`
`2
`
`
`
` INDEX
`EXAMINATION PAGE
`MAHESH S. MULUMUDI, MD
`BY MS. FREEMAN 6
`
`Page 3
`
` E X H I B I T S
`NO. DESCRIPTION PAGE
`Mulumudi 1030 US Patent and Trademark
` Office Decision Granting
` Institution of Inter
` Partes Review.............. 66
`
`Mulumudi 1020 Fedorov, et al article,
` 3D Slicer as an image
` computing platform for
` Quantitative Imaging
` Network.................... 132
`
`Mulumudi 1029 US Patent and Trademark
` Office Decision Granting
` Institution of Inter
` Partes Review.............. 57
`Mulumudi 1031 August 3, 2022 e-mail...... 107
`Mulumudi 1032 United States Patent
` 10,945,807 B2.............. 67
`
`Mulumudi 1033 Azimi, et al article,
` Augmented Reality Goggles
` with an Integrated
` Tracking System for
` Navigation in
` Neurosurgery............... 115
`
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`Medivis Exhibit 1022
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`Page 4
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`Mulumudi 1034 Amira 5 User's Guide....... 120
`
`Mulumudi 1037 Chen, et al article,
` Development of a surgical
` navigation system based
` on augmented reality
` using an optical
` see-through head-mounted
` display.................... 143
`
`Mulumudi 1038 Document titled
` Documentation/4.6./
` SlicerApplication/
` MainApplicationGUI......... 148
`Mulumudi 1039 Document titled 3D
` Visualization of DICOM
` Images for Radiological
` Applications............... 149
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`Medivis Exhibit 1022
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`4
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`Page 5
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` - - -
` DEPOSITION SUPPORT INDEX
` - - -
`
`Direction to Witness Not to Answer
`PAGE LINE
`None.
`
`Request for Production of Documents
`PAGE LINE
`None.
`
`Stipulations
`PAGE LINE
`None.
`
`Questions Marked Highly Confidential
`PAGE LINE
`None.
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`Medivis Exhibit 1022
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`Page 6
`
` P R O C E E D I N G S
` * * *
`Whereupon,
` MAHESH S. MULUMUDI, MD,
`being first remotely duly sworn to testify to
`the truth, the whole truth, and nothing but the
`truth, was examined and testified as follows:
` EXAMINATION
`BY MS. FREEMAN:
` Q. Good morning, Dr. Mulumudi.
` A. Hi, good morning.
` Q. Is there any reason why you can't
`give truthful testimony today?
` A. No.
` Q. Do you have any illness that can
`affect your ability to provide truthful
`testimony?
` A. No.
` Q. Have you taken any medication that
`can affect your ability to provide truthful
`testimony?
` A. No.
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`Medivis Exhibit 1022
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`6
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`Page 7
` Q. Do you understand that no one can
`assist you in answering questions in this
`deposition?
` A. Yes.
` Q. Is there anybody in the room with
`you today?
` A. No.
` Q. Are you using any device or software
`to receive assistance in answering questions?
` A. No.
` Q. Do you agree not to accept any
`assistance in answering any questions in this
`deposition?
` A. I agree.
` Q. Do you have any reference materials
`in front of you?
` A. I don't have, but I have them on my
`computer.
` Q. You have done your computer. Can
`you explain what you mean by that?
` A. Because my own deposition
`declaration that I wrote.
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`Page 8
` Q. Okay. Would you close that out,
`please?
` A. Okay.
` Q. Let me know when you're --
` A. It's closed, yeah.
` Q. Dr. Mulumudi, what country were you
`born in?
` A. India.
` Q. What is your mother tongue?
` A. Telugu.
` Q. What language did you speak with
`your family growing up?
` A. English and Telugu.
` Q. How many languages do you speak?
` A. Three.
` Q. What languages do you speak?
` A. I speak English, Telugu, and Hindi.
` Q. Have you noticed any differences
`between British English and American English?
` A. I don't think so, no.
` Q. Are you familiar with the English
`word "being"?
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`Page 9
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` A. I'm sorry, what?
` Q. Are you familiar with the English
`word "being"?
` A. Being? Yes. Why?
` Q. Is the English word "being" a
`technical word?
` A. All I know is a literary English
`word. I don't know if it's technical or not.
` Q. So you don't know whether the
`English word "being" has a technical meaning?
` A. I don't think so. This can be a
`human being, it can be a being as in a being,
`but I don't know of anything else technical
`about it.
` Q. So are you saying you don't know
`whether it's a technical word?
` A. I don't.
` Q. What does the English word "being"
`mean?
` A. Being is a thing, human being, or
`animal being or plant being.
` I'm assuming you're using B-E-I-N-G.
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`Page 10
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` Q. Yes.
` A. Okay.
` Q. Does the word "being" have any other
`meaning that you're aware of?
` A. I'm being asked questions right now,
`that's a being.
` Q. Can you explain what being means in
`that context?
` A. As it is happening.
` Q. Are you aware of any other meaning
`of the word "being"?
` A. Not that I know of.
` Q. Are you familiar with the English
`word "having"?
` A. Yeah. I do, yeah. I am having a
`cup of coffee.
` Q. Is the English word "having" a
`technical word?
` A. I use it as an English word to
`express meaning, that's about it. I don't know
`if it's a technical word.
` Q. So you don't know whether the
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`Medivis Exhibit 1022
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`Page 11
`English word "having" is a technical word?
` A. I don't.
` Q. What does the English word "having"
`mean?
` A. Can I ask a question?
` Q. Sure.
` A. What is the "technical" in your
`definition of "technical word"?
` Q. Do you understand the English word
`"technical"?
` A. I understand "technical word." What
`is the meaning of a "technical word" in your
`dictionary that you are asking me?
` Q. My dictionary doesn't matter for
`purposes of this deposition. I am asking
`questions, and you're providing answers.
` So do you understand --
` MR. HARMER: Objection.
` The questions are clearly vague. If
` he needs clarity to understand the
` question, that's appropriate.
` MS. FREEMAN: There's a rule against
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`Page 12
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` speaking objections.
`BY MS. FREEMAN:
` Q. Professor Mulumudi, do you
`understand the word "technical"?
` A. Technical is something that is
`technical that is mechanical, that is related to
`a specific purpose, but I don't know if you're
`asking me technical in terms of a technical
`technology, is it something to do with a
`technical process, is it to do with technical
`for a particular legal language or a medical
`language, or is it for expression of
`technicalities?
` That is the question I was asking
`about what do you mean by technical.
` Q. Okay. Applying your definition of
`technical, does the English word "having" have a
`technical meaning?
` MR. HARMER: Objection. Vague.
` You can answer if you understand.
` THE WITNESS: I don't understand.
` ///
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`Page 13
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`BY MS. FREEMAN:
` Q. What don't you understand about that
`question?
` A. I'm not completely understanding
`what do you mean by technical meaning of having.
` Q. Okay. We talked about the word
`"technical," and you said you understand that
`word, right?
` A. (Nodding in the affirmative.)
` Q. Okay. So applying your
`understanding of the word "technical," what is
`your lack of understanding of that word, of that
`question, does the English word "having" have a
`technical meaning?
` MR. HARMER: Objection. Vague,
` compound.
` Dr. Mulumudi, after I object you can
` answer, unless I specifically tell you not
` to answer.
` THE WITNESS: Got it.
` Technical is contextual, depends on
` the context you are applying it for. What
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`Page 14
` would you like me to say about technical,
` in what context? Technical as in general
` speaking English, technical as written in
` a legal language, technical written in a
` medical textbook, or technical in a
` technology paper? Which context do you
` want me to use the word "technical"?
`BY MS. FREEMAN:
` Q. Does the English word "having" have
`a technical meaning in any context that you're
`aware of?
` A. Not I'm aware of.
` Q. What does the English word "having"
`mean?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Having a cup of
` coffee, for example.
`BY MS. FREEMAN:
` Q. I'm sorry, I didn't hear. What does
`the English word "having" mean?
` MR. HARMER: Same objection.
` THE WITNESS: I think it's too vague
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`Medivis Exhibit 1022
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`Page 15
` of a question. I don't want to answer
` that.
`BY MS. FREEMAN:
` Q. Can you provide any definition of
`the word "having"?
` A. Yes.
` MR. HARMER: Objection. Vague.
` THE WITNESS: Having a cup of
` coffee.
`BY MS. FREEMAN:
` Q. Okay. Do you believe that using a
`word defines the word?
` MR. HARMER: Objection. Vague.
` THE WITNESS: I think it is too
` vague for me to answer these type of
` questions from you.
`BY MS. FREEMAN:
` Q. Can you provide any definition of
`the English word "having"?
` MR. HARMER: Asked and answered.
` THE WITNESS: I already explained
` what having is in my technical meaning to
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`Page 16
` me, which is having a cup of coffee,
` having a piece of cake.
`BY MS. FREEMAN:
` Q. Those are examples. Can you provide
`any definition at all for the English word
`"having"?
` A. No, I can't.
` MR. HARMER: Same objection. Vague.
`BY MS. FREEMAN:
` Q. Are the English words "having" and
`"being" synonyms?
` A. No.
` Q. What is the difference between the
`meaning of the English word "having" and the
`English word "being"?
` A. Being is a not directly related to a
`particular item; example, it's a definition of a
`thing or a process. Having is a -- is a verb,
`in a way, to say that I'm having cup of coffee,
`having a piece of cake, or actively doing
`something can be having.
` Q. Can you provide any other definition
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`of the word "having"?
` A. These are the only ones that I know
`of.
` MR. HARMER: Vague.
`BY MS. FREEMAN:
` Q. Are you familiar with the English
`word "shape"?
` MR. HARMER: Objection.
` THE WITNESS: Yes. Yes. English
` word "shape" is shape.
`BY MS. FREEMAN:
` Q. Is the English word "shape" a
`technical word?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Not that I know of.
` Depends on context.
`BY MS. FREEMAN:
` Q. What does the English word "shape"
`mean?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Shape of a cup, shape
` of a fingernail.
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`BY MS. FREEMAN:
` Q. Dr. Mulumudi, you've just given me
`two examples. Can you give me any definition of
`the English word "shape"?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Shape is a form.
` Defining a form is a shape.
`BY MS. FREEMAN:
` Q. Can you give me any other definition
`of the English word "shape"?
` MR. HARMER: Objection. Asked and
` answered, vague.
` THE WITNESS: No.
`BY MS. FREEMAN:
` Q. Are you familiar with the English
`word "confine"?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Context, please?
`BY MS. FREEMAN:
` Q. Are you familiar with the English
`word "confine" in any context?
` A. Yes.
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` MR. HARMER: Objection.
` THE WITNESS: Confine is being in a
` certain spot, confined to a corner,
` confined to a place, confined to a time.
` What context is the important one there?
`BY MS. FREEMAN:
` Q. Is the English word "confine"
`technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Everything can be
` technical in the right context.
`BY MS. FREEMAN:
` Q. Do you know the context in which the
`English word "confine" is technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: No.
`BY MS. FREEMAN:
` Q. How do you define the English word
`"confine"?
` MR. HARMER: Objection. Vague,
` asked and answered.
` THE WITNESS: To conform to or to be
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` placed in a certain spot.
`BY MS. FREEMAN:
` Q. Can you provide any other definition
`of the English word "confine"?
` MR. HARMER: Objection. Vague.
` THE WITNESS: No.
`BY MS. FREEMAN:
` Q. Are you familiar with the English
`word "slice"?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Yes. A piece of.
`BY MS. FREEMAN:
` Q. Is the English word "slice"
`technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Depends on the
` context.
`BY MS. FREEMAN:
` Q. Is the English word "slice"
`technical in any context that you're aware of?
` MR. HARMER: Same objection.
` THE WITNESS: It's contextual.
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` Unless we define a context, I cannot say
` if it's technical, non-technical. It's --
`BY MS. FREEMAN:
` Q. I'm not -- sorry, Dr. Mulumudi, I
`think I inadvertently interrupted you. I
`thought you were done speaking.
` A. That's okay.
` So I'm saying that it's contextual,
`number one, and the other one I was mentioning
`is depends on the context and where it's being
`used.
` Q. Okay. Can you identify a context in
`which the English word "slice" is technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: I'm having trouble
` with understanding when you keep asking
` about "technical." Would you say a
` context, please?
`BY MS. FREEMAN:
` Q. I'm asking if you're aware of a
`context in which the English word "slice" is
`technical.
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` A. In a baker's context, slice of a
`bread is a slice.
` MR. HARMER: Objection.
`BY MS. FREEMAN:
` Q. Okay. So are you saying in a
`baker's context the English word "slice" is
`technical?
` A. Yes, for him it's technical. For a
`bakery, or a baker, that's a technical term.
` Q. Okay. Are you aware of any other
`context in which the English word "slice" is
`technical?
` A. For a cake, slice of a cake is a
`technical term.
` Q. Okay. Are you aware of any other
`context in which the English word "slice" is
`technical?
` A. In medicine, for example, a slice
`can be a piece.
` Q. Are you aware of any other context
`in which the English word "slice" is technical?
` A. It can be any context. If you give
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`me a context, it will be easier, but you seem to
`be quite open about context here, so I'll keep
`telling about contextual things.
` So let us see here. For an image,
`it can be a slice, meaning a piece. Or for that
`matter, if you think about in surgery, you can
`say slice can be to cut. And slice can also be
`as a technical term if somebody is slicing the
`data, for example. In computer industry, they
`use the word "slice."
` So technicality about any word is
`contextual.
` Q. In the context of an image, the
`English word "slice" is technical, is that
`correct?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Anything can be made
` technical depending upon the context.
`BY MS. FREEMAN:
` Q. Okay. So I'm asking you in the
`context of an English -- image, sorry, is the
`English word "slice" technical?
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` MR. HARMER: Same objection.
` THE WITNESS: Yes, it can be.
`BY MS. FREEMAN:
` Q. Can you say whether it is or it
`isn't?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Yes, it is.
`BY MS. FREEMAN:
` Q. Okay. In the context of the
`computer industry, is the English word "slice"
`technical?
` A. I tend to use the word "slice" for
`slicing the data. If it is technical or not
`is -- depends upon who is using it. Some people
`can use "partition" the data.
` Q. When you use the English word
`"slice" in the context of the computer industry,
`is the English word "slice" technical?
` A. It can be. Depends on who I'm
`speaking with.
` Q. So when you use the English word
`"slice" in the context of the computer industry,
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`you may or may not be using it as a technical
`word?
` A. Depends on the context. If I'm
`using it for certain population of people that
`I'm speaking with, it is technical.
` Q. Who would you be speaking to in
`which you would use the word "slice" in a
`technical sense?
` A. If my computer engineers are slicing
`the data, they try to slice it in this direction
`of the data and see what we have, and sometimes
`I will say, I'll partition the database in this
`way and see how it happens.
` Q. How would the meaning of the word
`"slice" differ if you weren't using it in a
`technical sense in the context of the computer
`industry?
` A. Can you repeat the question, please?
` Q. How would the meaning of the word
`"slice" differ if you weren't using it in a
`technical sense in the context of the computer
`industry?
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` MR. HARMER: Objection. Calls for
` speculation.
` THE WITNESS: In computer industry
` if I use the word "slice" and -- let us
` slice the information, I will say this to
` my engineers, or I'll say, Let us slice
` the data.
`BY MS. FREEMAN:
` Q. Okay. Am I right in understanding
`that you said you could use the word "slice" in
`a technical sense and in a non-technical sense
`in the context of the computer industry?
` A. Yes.
` Q. Okay. How would the -- how would
`the meaning of the word "slice" differ in the
`context of the computer industry depending on
`whether you were using it in a technical sense
`or not?
` A. Can you repeat the question, please?
` Q. How would the meaning of the word
`"slice" differ in the context of the computer
`industry depending on whether you were using it
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`
`in a technical sense or not?
` A. If I'm using in a technical sense, I
`will tell them, Slice the data, I'm talking
`about the data here, or sometimes I might say,
`Let us slice the information. If I say to slice
`the information, that can be defined as
`non-technical. If I say slice the data, that
`may be viewed as technical.
` Q. Okay. You've given me examples of
`what you might be referring to as an object of
`the slice, but can you tell me how the meaning
`of the word "slice" may differ?
` A. It wouldn't differ. It's the way
`you are expressing it.
` Q. Are you familiar with the English
`noun "layer"?
` A. Yes.
` Q. Is the English word "layer"
`technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Depends on the
` context, please.
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`BY MS. FREEMAN:
` Q. Are you aware of the English word
`being a technical word in any context?
` MR. HARMER: Objection. Vague,
` ambiguous.
` THE WITNESS: Depends on the context
` it's being utilized, and it's technical to
` one expertise or one group of people where
` it's non-technical for other expertise or
` other groups of people. The same word
` will be different for different groups.
`BY MS. FREEMAN:
` Q. In what context would the English
`word "layer" be technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: In medicine, in
` surgery we use the word "layer," meaning
` the layer of tissue, for example, or
` expose the layers.
`BY MS. FREEMAN:
` Q. In the context of medicine, what
`does the English word "layer" mean?
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` A. Layer is -- a defined stratum can be
`a layer.
` Q. All right. You just provided an
`example. Can you provide me a definition of the
`word "layer" in the context of medicine?
` A. Can I reference a dictionary?
` Q. I'm asking you to provide your
`answer without referring to any reference.
` A. I didn't realize that we are doing
`verbal language skills here, so I will try to
`explain this.
` Technical word "layer" is a certain
`thickness, defined substance in the human body
`can be a layer.
` Q. Okay. You say "a certain
`thickness." Can you be more specific about the
`thickness required for a layer?
` A. It can be any thickness.
` Q. Okay. So a layer is not limited by
`thickness?
` A. No.
` Q. So a layer is -- and your definition
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`is a "defined substance in the human body"?
` MR. HARMER: Objection.
` THE WITNESS: Not my definition. In
` the context -- sorry, Joe, go ahead.
` MR. HARMER: Objection. Misstates
` testimony.
` Thank you.
` THE WITNESS: In the context of
` medicine and especially human anatomy is
` what I described.
`BY MS. FREEMAN:
` Q. Can you -- I'm sorry, I don't think
`I understood what you described. Can you
`describe the definition of layer in the context
`of medicine?
` MR. HARMER: Objection. Vague,
` ambiguous.
` THE WITNESS: Medicine is a very
` large field. Where do you want me to go?
`BY MS. FREEMAN:
` Q. Do you know any definition of layer
`in the context of medicine?
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` A. Medicine is a large field. Can you
`define medicine, please?
` Q. I'm asking you in any part of
`medicine, context of medicine, can you define
`layer?
` A. I think I already described it.
`Layer is a defined substance that conforms
`itself into a stratum, or a certain thickness is
`a layer, and the thickness is of varying depths
`and can be variable. It can be very thin to
`very large. They all are construed "layer" in
`medicine. That is in the context of human body
`and human tissue.
` Q. Can you explain what you mean by the
`word "stratum" in your answer?
` A. Stratum is a -- for me, it's a
`medicine word that we use for layers. Stratum
`is also used as layers.
` Q. Okay. So --
` A. Stratification is separation of
`tissues by certain amount of characteristics.
`That is where the stratum comes from.
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`Stratification is the verb, and stratum would be
`what would come out of a stratification.
` MS. FREEMAN: I hear a child's voice
` in the background. Could someone please
` mute themselves if they have a child
` making noise in the background?
` Q. Are the English words "slice" and
`"layer" synonyms?
` A. They're not.
` Q. What is the difference between a
`slice and a layer?
` A. Layer is more of a natural
`confirmation of the tissues in the context of
`human tissue and body. Slice is something that
`is created off a human body or a tissue by an
`operator.
` Q. Are you familiar with the English
`term "3D"?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Can you expand the
` term "3D," please?
` ///
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`BY MS. FREEMAN:
` Q. Are you familiar with the English
`term "3D"?
` A. I don't know what "D" stands for.
`Do you mean three-dimensional, or are you asking
`something else?
` Q. So when I say the word "3D" to you,
`you need clarification as to whether D refers to
`dimension?
` MR. HARMER: Objection.
` Argumentative.
` THE WITNESS: Because you're asking
` very vague questions, so I need to be very
` concrete about what exactly you're asking
` me.
`BY MS. FREEMAN:
` Q. Okay. Are you familiar with the
`term "3D," which is the Arabic numeral 3
`followed by the capital letter D?
` MR. HARMER: Objection. Vague.
` THE WITNESS: In the most common
` parlance, 3D is three-dimensional.
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`BY MS. FREEMAN:
` Q. Is 3D technical?
` A. Depends on context.
` Q. Is 3D non-technical?
` A. Yes. My kids go watch a
`three-dimensional movie, and they don't consider
`it as a technical term.
` Q. So are your children the judge as to
`whether 3D is a technical word?
` MR. HARMER: Objection.
` Argumentative.
` THE WITNESS: Since we're using very
` vague definitions and asking -- that's why
` I'm asking. I'm telling you in a
` contextual way, so to make it clear.
`BY MS. FREEMAN:
` Q. What context is the term "3D"
`technical?
` MR. HARMER: Objection. Vague.
` THE WITNESS: It can be in the
` context of imaging, for example. It can
` be 3D, meaning three-dimensional imaging.
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` D is a dimension, that's what the
` definition should be.
`BY MS. FREEMAN:
` Q. In the context of imaging, is 3D
`technical?
` A. Yes.
` Q. What does the term "3D" mean in the
`context of imaging?
` MR. HARMER: Objection. Vague.
` THE WITNESS: Three-dimensional can
` be -- in the context of imaging,
` three-dimension is ability to see the
` object of interest in multiple angles and
` multiple depths, and also related to
` multiple textures.
`BY MS. FREEMAN:
` Q. Is there any other meaning of the
`word "3D" in the context of imaging?
` A. Not that I know of.
` Q. Are you aware of any other
`definition of the term "3D"?
` A. Besides what I explained, no.
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` Q. What would 3D mean to your children
`when they went to see a 3D movie?
` MR. HARMER: Objection. Relevance.
` THE WITNESS: For them, objects
` appear them --
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