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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`CASE NO. PGR2015-00019
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`US ENDODONTICS LLC,
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`PETITIONER,
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`vs.
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`GOLD STANDARD INSTRUMENTS, LLC,
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`PATENT OWNER.
`8 *******************
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`DEPOSITION OF WALTER ZANES, a witness called on
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`behalf of the Patent Owner, pursuant to the rules and
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`provisions of the U.S. Patent and Trademark Office,
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`before Lisa McDonald Valdario,
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`(CSR #130093), a
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`Registered Professional Reporter, Certified Realtime
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`Reporter, and Notary Public in and for the
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`Commonwealth of Massachusetts, at the Offices of G&M
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`Court Reporters, Ltd., 42 Chauncy Street, Boston,
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`18 Massachusetts 02111-2211, on Monday, April 11, 2016,
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`commencing at 12:50 p.m.
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`GOLD STANDARD EXHIBIT 2040
`US ENDODONTICS v. GOLD STANDARD
`CASE PGR2015-00019
`
`

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`Page 2
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`APPEARANCES:
` PATTERSON BELKNAP WEBB & TYLER LLP
` 1133 Avenue of the Americas
` New York, New York 10036-6710
` BY: Abhishek Bapna, Esquire
` abapna@pbwt.com
` 212.336.2000
` Attorney for the Petitioner
`
` ROTHWELL, FIGG, ERNST & MANBECK, P.C.
` 607 14th Street, N.W., Suite 800
` Washington, D.C. 20005
` BY: Derek F. Dahlgren, Esquire
` ddahlgren@rfem.com
` 202.783.6040
` Attorney for the Patent Owner
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`Page 3
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` I N D E X
`WITNESS DIRECT CROSS REDIRECT RECROSS
`WALTER ZANES
`BY MR. DAHLGREN 5
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` E X H I B I T S
`No. Description Page
`Exhibit 2023 and 1015 referenced
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` P R O C E E D I N G S
` WALTER ZANES
` A witness called for examination, having been
` duly sworn, testified as follows:
` DIRECT EXAMINATION
`BY MR. DAHLGREN:
`Q Good afternoon, Mr. Zanes. Could you please state
` your name and address for the record. And
` actually before that, I should introduce myself.
` I'm Derek Dahlgren representing the patent owner,
` Gold Standard Instrument LLC in PGR2015-0019.
`A Do you want my personal address?
`Q So if you could please just state your name and
` personal address, please.
`A Yes, Walter Zanes, 387 Pleasant Street, Laconia,
` New Hampshire 02346.
`Q And Mr. Zanes, I'm handing you what's been marked
` as Exhibit 2023. This is Patent Owner Gold
` Standard Instrument LLC's Notice of
` Cross-Examination of Walter Zanes.
`A Um hmm.
`Q Have you seen this document?
`A I have not.
`Q Okay. You can just take a second to take a look
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` at the document.
` You understand that you are being deposed in
` a proceeding before the patent office, the U.S.
` Patent and Trademark Office, is that correct?
`A Yes.
`Q And you understand that's the same proceeding in
` which you prepared a declaration, is that correct?
`A Yes. I was unaware at the time, but yes.
`Q Okay. Have you ever been deposed before?
`A No.
`Q Okay. So I'm just going to go over some ground
` rules. Our -- my questions and your answers are
` being recorded today. To make that job easier for
` the court reporter, we need to speak up, need to
` avoid giving nonverbal answers like nodding your
` head. It's important to have a record. Can you
` do that today -- is that okay?
`A Yes.
`Q Now, on occasion I may ask a question that it's
` not clear what I'm asking. You may not understand
` it. If I do that, please let me know that you
` don't understand the question. I'll try to
` rephrase it to make sure that you do understand
` what I'm asking. That sound fair?
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`A Yes.
`Q And if you don't hear the question clearly, you
` can ask me to repeat it or ask the court reporter
` to repeat it as well. Okay?
`A Okay.
`Q We're interested in finding out certain things
` about your declaration, your background. So it's
` important to have complete answers to the
` questions I'm going to ask. Does that sound okay?
`A Yes.
`Q Okay. If, at any time, you recall additional
` information, maybe earlier I asked you a question
` and you gave a partial response, if you do recall
` additional information, you can just let me know,
` and you can then provide whatever additional
` information that you just recalled. Does that
` make sense?
`A Yes.
`Q We're probably going to take breaks every hour,
` hour and a half. Does that sound okay?
`A Yes.
`Q If you need to take a break earlier, just let me
` know, and then after, you know, I've asked the
` question, we've gotten your answer, we can try to
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`Page 7
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` take a break then.
`A Yes.
`Q Okay. Is there any reason you can't give truthful
` testimony today?
`A No.
`Q So I'd like to first talk about your employment
` history. What's your current occupation?
`A Quality manager.
`Q Is that at Bodycote?
`A Bodycote Thermal Processing, yes.
`Q How long have you had that position?
`A Little over a year.
`Q What did you do before that?
`A I was a quality engineer with Bodycote.
`Q When did you start in that position?
`A That position was approximately two years. Prior
` to that, I was an inspector with Bodycote, so I've
` been with Bodycote for ten. Ten years in August.
`Q Okay. And prior to Bodycote, were you employed
` anywhere?
`A Yes. I did plumbing work.
`Q Okay. And how long did you do that?
`A I did plumbing work for about four years. I
` joined the Marine Corps and I was discharged,
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`Page 8
` medically discharged from the Marine Corps.
`Q So before you were a plumber, you were in the
` Marine Corps?
`A After. In between.
`Q Oh, in between. Okay.
`A Not very long.
`Q And what did you do in the Marine Corps?
`A I actually got discharged during training.
`Q Oh, you did. Okay.
` So as the quality manager at Bodycote, what
` are your job responsibilities?
`A Overseeing the product quality.
`Q What does that entail?
`A Whatever a customer asks for. So different
` processes, make sure they're done properly. We
` heat treat steel, so usually they'll be looking
` for a particular hardness, so we ensure that the
` product is set to the correct hardness;
` certifications.
`Q Okay. So do you do testing after you do these
` heat treatments to confirm that a product is
` within specs?
` MR. BAPNA: Objection.
`A If the customer asks for it.
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` MR. BAPNA: Objection. Form.
`Q Do you heat treat any other materials other than
` steel?
`A No.
`Q And as a quality engineer at Bodycote, what were
` your job responsibilities?
`A As a quality engineer?
`Q Yes.
`A The assistant to the quality manager. I generated
` heat treat process instructions; worked in the
` inspection department.
`Q What work did you do in the inspections
` department?
`A Hardness testing.
`Q And you talked about -- I think you mentioned
` preparing heat treat instructions?
`A Um hmm.
`Q Can you kind of describe to me what that entails?
`A So like a router that would follow the product
` through the plant.
`Q And approximately, if you had to estimate, how
` many different instructions did you prepare for
` various heat treatment processes?
` MR. BAPNA: Objection to form.
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`A How many different ones?
`Q Yeah.
`A I don't know how you want me to answer that. It's
` kind of a strange question because we do 50 to a
` hundred orders a day.
`Q Does each one have a different set of
` instructions?
`A Each one gets its unique, a unique set of
` instructions that goes with that order, yes.
`Q Okay. So there could be thousands and tens of
` thousands?
`A There could be similar -- processes could be
` similar, the processes could be the same, but
` they're going to get their own individual --
`Q Okay.
`A Yeah.
`Q So the instructions may not be unique -- correct?
` Is that fair?
`A Fair. Yeah.
`Q Okay. How many different products, if you had to
` estimate, have you prepared heat treatment
` instructions for?
`A Myself personally?
`Q Yes.
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`A A lot.
`Q Okay.
`A Yeah. I mean --
`Q You were doing that --
`A I've been with the company, and I, on occasion,
` I'll still do that in my current position. So 10
` years worth is -- it's a lot.
`Q Okay. And how do you select the heat treatment
` that you're going to use?
` MR. BAPNA: Objection. Form.
` THE WITNESS: Still answer it?
` MR. BAPNA: You can answer.
`A Oh, okay. How do I select it? Based off purchase
` order requirements, specifications, material
` specifications. Yeah.
`Q Okay. And as an inspector at Bodycote, what were
` your job duties in that position?
`A Reviewing processes, doing various hardness
` testing. I also generated the processes in that
` position too.
`Q Okay.
` So you mentioned that you prepared the
` instructions based off of the purchase order
` requirements. Could you just explain to me kind
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` of what those requirements would be?
`A It could be final, final hardness properties.
` Could be temperatures, times.
`Q When you say "temperatures," what do you mean? In
` the purchase order requirements, it could be --
`A Correct. They might say: Here is a piece of
` material. 4140 steel. We want to heat treated it
` at 1500 degrees for two hours. And that's what we
` would put on the instructions.
`Q Okay. So it's certain times they would actually
` essentially dictate the process.
`A Correct, yes.
`Q So that was -- I think you said temperatures and
` times. So you're referring to them providing you
` with the instructions essentially.
`A Right.
`Q If a customer gives you a desired hardness that
` they want for steel, are you able to figure out
` the appropriate heat treatment process to use to
` achieve that hardness?
`A Yes.
`Q Is that pretty well-characterized, that
` relationship between kind of the heat treatment
` and the resulting hardness of the material?
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`A Yes.
`Q So what type of heat treatments does Bodycote
` offer its customers?
`A Type of heat treatments. We do like vacuum heat
` treatment. We do oil quench heat treatments,
` tempering, stress relief, anneal.
`Q What's -- when you say anneal heat treatments,
` what does that mean?
` MR. BAPNA: Objection. Scope. Relevance.
` You can answer unless I say not to.
`A Okay. To soften, to soften the material.
`Q So you mentioned vacuum, oil quench, tempering,
` stress relief, anneal. Are there any others that
` you can think of right now?
`A Not off the top of my head. I'm sure there are
` some other.
`Q Okay. So for the vacuum heat treatment, is -- I
` guess, could you describe that to me briefly?
`A Yeah, so the parts will be put into a furnace, and
` the furnace would pump down, pump all the
` atmosphere oxygen out of the furnace, and maintain
` a negative pressure throughout the cycle, and
` that's to protect the material from any
` oxidization.
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`Q When you pump out the oxygen, is that a hundred
` percent effective, or is it like 99 percent
` vacuumed -- do you know?
`A No, I can't answer that question.
`Q For the oil quench, could you briefly describe
` that heat treatment?
`A Yeah. So the parts are put into a furnace with
` what they call an endothermic atmosphere. It's a
` gas mixture that protects the parts from
` oxidization also, and then the parts move through
` the furnace and get cooled into oil, with oil.
`Q What type of atmosphere do you use for the oil
` quench heat treatment process?
`A It's endothermic. It's a gas mixture.
`Q Do you know what gases?
`A Not off the top of my head.
`Q Okay. And you mentioned tempering?
`A Um hmm.
`Q Could you briefly describe that, please?
`A Yeah. That follows a hardening process. It
` strengthens the material. It's usually done in an
` air atmosphere at a temperature range of usually
` 200 to 1100 degrees Fahrenheit.
`Q Okay. And you, I think, also mentioned a stress
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`Page 15
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` relief heat treatment?
`A Yeah.
`Q Could you please describe that?
`A Yeah, that removes any stress to steel caused from
` machining, or in any kind of bending to the steel
` to prevent any cracking fractures. Similar --
` it's a similar process to tempering.
`Q Okay. For -- just going back, for this
` endothermic one with the gas mix, you don't recall
` what particular gases are used; for example, argon
` or nitrogen?
` MR. BAPNA: Objection. Relevance.
`A No, because I don't want to mislead you.
`Q Can you just give me your best guess?
` MR. BAPNA: Objection. Form. Relevance.
`A It's a hydrogen mixture is my best guess.
`Q Okay.
` Do you do any heat treatments in a salt
` bath?
`A No.
`Q Do you do any coatings at Bodycote?
`A At our facility, we don't.
`Q Are you familiar with different types of coatings?
` MR. BAPNA: Objection. Foundation. Form.
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`A Not really.
`Q Do you ever heat materials using an electrical
` current?
` MR. BAPNA: Objection. Relevance.
`A Yes. Yeah, that's a process called induction
` hardening.
`Q Could you briefly describe that, please?
`A Yeah. So if a customer wants a part hardened, and
` they only want a certain area of that part to be
` hardened, we take that part and we'd put it into
` a -- in a copper coil that wraps around the part.
` Doesn't come in contact with it, but the electric
` current will flow through that copper coil and
` will heat the part up, and then they'll either
` quench it in water or oil.
`Q Okay. So that allows you to selectively heat
` parts of it?
`A Yes, localized heat treat.
`Q Do you have any other methods you use for doing
` localized heat treatment?
` MR. BAPNA: Objection. Scope, relevance.
`A We don't.
`Q Is the induction hardening a difficult process for
` you guys --
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`Page 17
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` MR. BAPNA: Same objection.
`Q -- to use?
`A It's a skilled -- it's a skilled process, but I
` wouldn't really call it a difficult process.
`Q Do you ever use hot air guns for heating?
` MR. BAPNA: Objection. Scope, relevance.
`A No.
`Q Do your customers specify the atmosphere that they
` want you to use for the heat treatment in these
` purchase order requirements?
`A They could. They could. They don't always.
` We're allowed to choose at times. Other times,
` the process is dictated through a specification,
` and the atmosphere is dictated through --
`Q Okay. So in this proceeding, you performed a heat
` treatment on certain Endodontic files, right?
` MR. BAPNA: Objection. Form.
`A Yes.
`Q Was that the first time you had worked with nickel
` titanium?
` MR. BAPNA: Objection. Form.
`A No. It was the first time we had worked with it
` to this process.
`Q Could you briefly describe your prior work with
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` nickel titanium?
`A Not off the top of my head.
`Q Did it involve heating nickel titanium?
`A Yes.
`Q And what heat treatment process did you use for
` the nickel titanium that you worked with prior to
` your involvement in this proceeding?
`A I don't recall.
`Q Do you recall why you were doing the heat
` treatment on the nickel titanium?
` MR. BAPNA: Objection. Relevance.
`A No, I don't recall that either.
`Q What do you recall about the prior work you did
` with nickel titanium?
`A We heat treat many materials. So just the
` familiar, the familiarity with nickel titanium,
` that if I were at my office, I could probably tell
` you what we had done. But usually, it's -- we do
` a lot of aerospace parts. Even raw materials
` we'll get in that aren't even machined, we'll just
` get bar materials, so.
`Q Do you recall what application this nickel
` titanium was being used for that you had worked
` with prior to your involvement in this proceeding?
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` MR. BAPNA: Objection. Relevance.
`A I don't.
`Q So you mentioned before that you're able to change
` the hardness of steel based on the heat treatment
` that you select.
`A Yes.
`Q Is that correct?
`A Yes.
` MR. BAPNA: Objection. Form.
`Q Do you have an understanding how you can change
` the properties of nickel titanium based on heat
` treatments?
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A My experience with nickel titanium is very
` limited, so I would have to research that.
`Q So I guess the question is -- I don't know if that
` really responded to my question, Mr. Zanes, so do
` you have an understanding though how you can
` change the properties of nickel titanium based on
` heat treatments?
` MR. BAPNA: Same objections. Form.
` Relevance, scope.
`A So if a customer sent me nickel titanium, I would
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`Page 20
` research the specs. It's not a common material
` that we see quite often. So I would have to
` research the specifications if the customer was
` asking for a particular heat treat.
`Q And you started at Bodycote, you said, around 10
` years ago?
`A 2006.
`Q Okay.
`A Yeah. August.
`Q If someone asked you to perform a heat treatment,
` do you assume they're referring to a heat
` treatment with this endothermic gas mixture?
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A We would use the atmosphere that's appropriate for
` the material.
`Q Okay. So when someone says: I want you to heat
` treat a product, you don't immediately assume that
` they're referring to any particular atmosphere
` type.
`A Correct.
`Q Okay. So you'd agree that if someone was
` referring to heat treating, that doesn't
` necessarily mean they're talking about heat
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`Page 21
` treating a product in an atmosphere that's
` unreactive with the product, right?
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A Say the question one more time.
`Q Sure. So you'd agree that if someone was
` referring to heat treating a product, that doesn't
` necessarily mean, after talking to you, about heat
` treating a product in an atmosphere that's
` unreactive?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A Correct.
`Q What durations do you typically use for your heat
` treatments?
` MR. BAPNA: Objection. Form.
`A Duration is based off the size of the part unless
` it's otherwise specified in a spec.
`Q Okay. So you have determined, based on the size
` of the material that you need to heat, it's
` characterized well enough that you can choose the
` appropriate duration.
` MR. BAPNA: Objection. Form.
`A Yes.
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`Q Is it fair to say that if there is more material,
` you need to use a longer heat treatment time?
` MR. BAPNA: Objection. Form.
`A Yes.
`Q Okay. Do you do any heat treatments for 10
` minutes?
` MR. BAPNA: Objection. Form.
`A Yes.
`Q What's the purpose of those 10 minute heat
` treatments?
` MR. BAPNA: Objection. Form. Relevance,
` scope.
`A It's a specification for the material. Also,
` there is another process that's called case
` hardening, and that takes the steel and adds a
` carbon layer to the steel. So the shorter the
` time, the less carbon is infused into the surface
` of the steel.
`Q Okay.
`A So that will be the purpose of, let's say, a 10
` minute duration of temperature will be to prevent
` excess carbon from going in when they only want a
` fine layer.
`Q Okay. If you weren't doing a coating with carbon,
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`Page 23
` would you expect a 10 minute heat treatment to
` have any appreciable effect on the material?
` MR. BAPNA: Objection. Form. Relevance,
` scope.
`A It could.
`Q It could. What type of effect could it have?
` MR. BAPNA: Same objections.
`A Based off the size of the material, the thickness,
` it could have a surface reaction to the material.
`Q Okay. Any other effects you can think of other
` than the surface reaction?
` MR. BAPNA: Same objections.
`A Not off the top of my head.
`Q Okay. Would you expect it to have an appreciable
` effect on the material's hardness if it was just
` 10 minutes?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A On the surface hardness, yes.
`Q Okay. And that could be because of surface
` reaction that you were referring to?
`A Yes.
` MR. BAPNA: Same objections.
`Q And if you make a material surface harder, does
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`Page 24
`
` that material become less flexible?
` MR. BAPNA: Objection to form. Scope,
` relevance.
`A Yes.
`Q So you mentioned you do some hardness testing at
` times on products that you have heat treated. Do
` you do any other types of tests?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A We do. We can check for the depth of a, let's say
` the carbon layer that I described going in. It's
` called case hardening. We can verify that. Or we
` can verify any carbon going in for -- let's say
` there was a lack of carbon going into the steel,
` we could verify that also.
`Q Okay. So is this case hardening -- you consider
` that to be a different process than like a
` coating. Is that fair?
` MR. BAPNA: Objection. Form. Relevance,
` scope.
`A Correct. It's not a coating because it's actually
` adding carbon into the material.
`Q Do you know if the carbon is reacting with the
` steel?
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`Page 25
` MR. BAPNA: Objection. Form. Scope,
` relevance. Derek, is it okay if I have a running
` objection to all of these lines of questions?
` MR. DAHLGREN: I think some are kind of
` relevant. I don't want to be difficult, but I
` think some of these -- I don't know if a running
` objection would be appropriate.
` MR. BAPNA: Okay.
` MR. DAHLGREN: If I get to an area where I
` think it's fine, it's okay. Sorry.
`Q So I think the -- yeah, so the question was: Do
` you know if the carbon, in this case, hardening
` process, if it's reacting with the steel?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A It makes the steel harder.
`Q But you're not sure if there is an underlying
` chemical reaction going on?
` MR. BAPNA: Same objection.
`A I'm not a metallurgist so really not a question I
` should answer.
`Q Well, do you have any understanding, based on your
` experience working at Bodycote for approximately
` 10 years?
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`
` MR. BAPNA: Same objections.
`A I have knowledge, but I don't want to just start
` guessing, so.
`Q Well, what's your best understanding?
`A It creates a reaction to the surface of the steel,
` yes.
`Q And after the heat treatments, do you do different
` types of quenching? I believe you mentioned an
` oil quench?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A Yes. The other parts could be quenched in oil.
` They could be quenched in gas, nitrogen, argon,
` helium, or could be just air. Or oil.
`Q You mention an argon quench. Could you briefly
` describe that, please.
` MR. BAPNA: Objection. Form. Scope
` relevance.
`A Argon gas -- the parts will be in a vacuum
` furnace. So after the duration of the soak time
` for the material, argon will be introduced into
` that furnace to cool the parts.
`Q Okay. And they're left in the furnace with the
` argon while they're cooling?
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` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A Correct, until they're below approximately 200
` degrees Fahrenheit.
`Q Do you know why argon is used?
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A It's an inert gas.
`Q And you also mentioned nitrogen?
`A Um hmm.
`Q Could you briefly describe how nitrogen is used in
` the quenching process?
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A It's the same as -- same process as argon.
`Q And why is nitrogen used?
` MR. BAPNA: Same objections.
`A It provides a faster quench rate than argon.
`Q Do you know why nitrogen is faster than argon?
` MR. BAPNA: Same objections.
`A I don't.
`Q And I think you also mentioned helium, is that
` right?
`A Yes.
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`Q Could you briefly describe that process for
` quenching?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A Yeah, it will be along the same lines of the argon
` and nitrogen. It's considered an inert gas also,
` and we rarely would use that. Only if a customer
` asked us to.
`Q Okay. Is there a reason why helium is
` occasionally used as opposed to argon and
` nitrogen?
` MR. BAPNA: Objection. Scope, relevance.
`A To my understanding, I don't understand why they
` would choose it.
`Q And you also mentioned air quenching?
`A Um hmm.
`Q Could you briefly describe that process?
` MR. BAPNA: Objection. Form. Scope,
` relevance.
`A Yeah. The parts will be processed in a furnace
` that runs with an air atmosphere. When the parts
` are done heat treatment, they'll be pulled out and
` placed in front of a fan.
`Q And finally, you mentioned oil. Could you briefly
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`
` describe that?
` MR. BAPNA: Objection. Form. Scope,
` relevance?
`A Well, the parts are at temperature. They're
` dropped in a oil bath to cool the parts.
`Q So in all instances where you used the quenching
` process, the parts are pulled out while they're --
` at whatever temperature they're being heated to,
` and then subjected to the quenching process, is
` that right?
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`A No. No, because the gas quenching is done while
` the parts are still in the furnace. The oil
` quenching is done -- they're also still in the
` furnace. It's an internal quench. So they move
` into a chamber, and they actually drop down into
` an oil bath.
`Q Oh, so you have an oil bath that's actually
` located in the furnace?
`A Just below the furnace, yes.
` MR. BAPNA: Objection. Form. Scope.
` Relevance.
`Q So these furnaces, are they, I guess -- I assume
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`Page 30
` that's an automated piece of equipment that does
` the heat treatment, and then moves a part into the
` oil bath -- is that correct?
` MR. BAPNA: Same objections.
`A Yes. The operator will push controls to do that,
` but yes.
`Q So now I'd just like to -- we talked about your
` employment history. Just want to talk about your
` education.
` You had said you're not a metallurgist. Do
` you have any formal training?
` MR. BAPNA: Objection. Form.
`A I have been internally trained. I don't have any
` formal training as far as a degree, if that's what
` you're asking.
`Q A degree or any type of program where you had
` learned about the work, the heat treating
` materials, and things of that nature?
`A It was primarily internally trained.
`Q Did you go to college?
`A I didn't graduate college, no.
`Q But you attended for a period of time?
`A I did.
`Q Okay. Where did you go?
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`Page 31
`
`A Southern New Hampshire University.
`Q And what were you studying there?
`A Business.
`Q Okay. And how long did you attend Southern
` University of New Hampshire?
`A Approximately, two years.
`Q And how long was, I guess, the duration of the
` program that you were taking there?
`A Four years.
`Q Four years, okay.
` And did you take any science or engineering
` classes while you were there?
`A No.
`Q So you mentioned internal training. Was this at
` Bodycote?
`A Yes.
`Q Do they have any formal internal training
` programs?
` MR. BAPNA: Objection. Form.
`A We do. We have training on file, yes.
`Q And did you undergo that training?
`A Yes.
`Q Can you briefly describe what that entailed?
`A Primarily, on-the-job training with supervision
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`Page 32
`
` from other properly trained personnel.
`Q Okay. Was there a specific duration that you're
` in a program, maybe like an apprentice following
` someone?
` MR. BAPNA: Objection. Form.
`A I can't recall that, no.
`Q Okay. You mentioned you had worked with nickel
` titanium at least one time before your involvement
` in this procee

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