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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`----------------------------
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`----------------------------
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`US ENDODONTICS LLC,
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`Petitioner,
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`- against -
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`GOLD STANDARD INSTRUMENTS, LLC
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`Patent Owner.
`
`Case No. PGR2015-00019
`
`1133 Avenue of the Americas
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`New York, New York
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`April 13, 2016
`
`1:00 p.m.
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`DEPOSITION OF ADAM KOZAK, held at the
`
`above-mentioned time and place, before Randi
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`Friedman, a Registered Professional Reporter,
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`212-279-9424
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`V eritext Legal Solutions
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`212-490-3430
`GOLD STANDARD EXHIBIT 2041
`US ENDODONTICS v. GOLD STANDARD
`CASE PGR2015-00019
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`----------------------------
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`----------------------------
`
`US ENDODONTICS LLC,
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`Petitioner,
`
`- against -
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`GOLD STANDARD INSTRUMENTS, LLC
`
`Patent Owner.
`
`Case No. PGR2015-00019
`
`1133 Avenue of the Americas
`
`New York, New York
`
`April 13, 2016
`
`1:00 p.m.
`
`DEPOSITION OF ADAM KOZAK, held at the
`
`above-mentioned time and place, before Randi
`
`Friedman, a Registered Professional Reporter,
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`212-279-9424
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`V eritext Legal Solutions
`www.veritext.com
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`GOLD STANDARD EXHIBIT 2041
`US ENDODONTICS v. GOLD STANDARD
`CASE PGR2015-00019
`
`
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`Page 2
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`APPEARANCES:
` PATTERSON BELLKNAP WEBB & TYLER, LLP
` Attorneys for Petitioner
` 1133 Avenue of the Americas
` New York, New York 10036
` BY: ABHISHEK BAPNA, ESQ.
`
` ROTHWELL, FIGG, ERNST & MANBECK
` Attorneys for Patent Owner
` 607 14th Street, N.W.
` Washington, D.C. 20005
` BY: DEREK F. DAHLGREN, ESQ.
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` STIPULATIONS
` IT IS HEREBY STIPULATED, by and between
`the attorneys for the respective parties hereto,
`that:
` All rights provided by the C.P.L.R.,
`and Part 221 of the Uniform Rules for the Conduct
`of Depositions, including the right to object to
`any question, except as to the form, or to move
`to strike any testimony at this examination is
`reserved; and in addition, the failure to object
`to any question or to move to strike any
`testimony at this examination shall not be a bar
`or a waiver to make such motion at, and is
`reserved to, the time of this action.
` This deposition may be sworn to by the
`witness being examined before a Notary Public
`other than the Notary Public before whom this
`examination was begun, but the failure to do so
`or to return the original of this deposition to
`counsel, shall not be deemed a waiver or the
`rights provided by Rule 3116, C.P.L.R., and shall
`be controlled thereby.
` The filing of the original of this
`deposition is waived.
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` * * *
` ADAM KOZAK, the witness herein,
` having been duly sworn, was examined and
` testified as follows:
` * * *
` EXAMINATION
`BY MR. DAHLGREN:
` Q Good afternoon. Can you please state
`your name and address for the record, please?
` A My name is Adam Kozak. Will my
`business address be okay?
` Q Actually, if you do your personal
`address, your residential address, that's all
`right.
` A Sure. So it's 81 Mount Vernon Street,
`and that's in Somerville, Massachusetts.
` MR. BAPNA: Just for the record,
` I'm Abhishek Bapna. I represent the
` petitioner in this proceeding, and today I
` represent Mr. Kozak in this deposition.
` MR. DAHLGREN: My name is Derek
` Dahlgren. I'm an attorney, I represent the
` patent owner, Gold Standard Instruments, LLC
` in this proceeding. This is PGR2015-0019.
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` A. Kozak
` (Exhibit 2024 was marked.)
`BY MR. DAHLGREN:
` Q I'm handing you what's been marked as
`Exhibit 2024. Take a look at that. This is
`patent owner Gold Standard Instrument, LLC's
`Notice of Cross-Examination of Adam Kozak.
` Have you seen this document before?
` A I have not.
` Q Okay. You can take a few minutes and
`look at it if you want, but do you understand
`today that you're here to testify in this
`proceeding regarding a certain declaration that
`you submitted?
` A I understand.
` Q Okay. Have you ever been deposed
`before?
` A I have not.
` Q Okay. So I'm just going to go over a
`few ground rules. Try to make this easier.
` A Sure.
` Q The first one is we need to get verbal
`responses to make it easier on the court
`reporter. It's hard to take down nodding heads
`and things like that. So can you do that today?
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` A. Kozak
` A Yes.
` Q Okay. Excellent.
` Now on occasion I may ask a question
`that you don't understand. It may not make
`sense. It may happen more often than I'd like.
`If I do that, will you let me know you don't
`understand the question and I'll try to rephrase
`it?
` A Yes.
` Q Same if you don't hear the question
`clearly. If you want me to repeat it, just ask.
`I'm happy to do that. Is that fair?
` A Okay.
` Q So we're going to try to take breaks
`every hour to hour and a half. If you need to
`take a break before then, just let me know, and
`once I've finished asking the question, you've
`answered it, we can try and take a break.
` Finally, is there any reason today
`that you can't provide complete and truthful
`answers to my questions?
` A There's no reason I can't provide
`complete answers.
` Q Okay. And truthful answers?
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` A. Kozak
` A And truthful answers, yes.
` Q So what's your current occupation?
` A I am a research scientist at Cambridge
`Polymer Group.
` Q How long have you been in that
`position?
` A Four years in August.
` Q And what are your job responsibilities
`in that position?
` A So my responsibilities there are
`multiple. I'm the projects manager for projects
`that involve mechanical characterization of
`materials and devices. I also perform -- also
`manage projects involved with the
`characterization of materials and devices.
` Q So what type of -- I think you said
`mechanical characterizations is one aspect. What
`type of mechanical characterizations do you do?
` A So Cambridge Polymer Group performs a
`variety of mechanical tests, including standard
`tensile testing, compression testing, flexural
`testing. We perform dynamic mechanical analysis.
`We perform rheological analysis on materials and
`on devices.
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` A. Kozak
` Q Pardon my ignorance, what is
`rheological?
` A Rheological characterization refers to
`the properties of fluids, specifically viscosity
`and the physical elastic properties of fluid
`materials.
` Q How do you spell that, to make it
`easier for the court reporter?
` A R-H-E-O-G-O-L --
` Q R-H-E-O logical?
` A R-H-E-O logical, yes.
` Q Thank you.
` What type of materials have you done
`these mechanical characterizations of?
` Excuse me. That question is a little
`clunky.
` What type of materials have you
`characterized mechanically as part of your work
`at Cambridge?
` A So we work with a variety of clients
`and a variety of material. We work on polymeric
`materials. We work on ceramics. Some metals.
`Primarily testing polymeric materials.
` Q And what metals have you performed
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` A. Kozak
`these mechanical characterizations on as part of
`your work at Cambridge?
` A To give you a full list of the metals
`that we work on, I need to go back and kind of
`review the projects that I was a part of.
` Q What's your best recollection today
`regarding what metals you've worked on?
` A Again, to give you an accurate
`response I need to go back, but these may be
`metals that are commonly used, say, in the
`orthopedic industry. Metals that are commonly
`used in the metal device industry. Those would
`be the types of metals that we have tested in the
`past.
` Q Okay. Can you give me your best
`recollection about these -- identifying any of
`these specific metals you've worked with?
` MR. BAPNA: Objection, scope and
` relevance.
` THE WITNESS: So these metals
` would include things like stainless
` steel-type devices, titanium-type devices.
` Devices that would fall under the categories
` I described previously.
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` A. Kozak
`BY MR. DAHLGREN:
` Q Any others that you can recall right
`now?
` A None that I can recall right now, no.
` Q Before your -- I guess other than the
`work that you did in connection with this
`proceeding, have you done any work with nickel
`titanium alloys?
` A The -- again, to give you an accurate
`answer to which projects I've dealt with those
`devices, I would need to go back. To the best of
`my knowledge, we have done testing that includes
`some nickel titanium alloys, but again...
` Q Were you involved in that testing?
` A I'm sorry, can you rephrase?
` Q Absolutely. Were you involved in
`testing that the Cambridge Group did -- excuse
`me.
` Were you involved in any of the
`testing the Cambridge Group did regarding nickel
`titanium?
` A Is there -- I'm sorry. Just to
`rephrase, because testing can cover a wide range
`of types of tests. Are there particular types of
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` A. Kozak
`tests that you're referring to or just testing in
`general?
` Q Testing in general. And we can get to
`the specific testing.
` A Sure. Sure. So to answer your
`question, we -- again, we primarily test
`polymeric materials. Metals is not -- is a
`subset of what we primarily test. I cannot
`recall another project right now that would -- in
`which -- in which I was part of a project that
`involved testing before this project.
` Q And you're talking about testing
`concerning nickel titanium materials?
` A Right. Right.
` Q So you don't recall any personal
`involvement in any testing at the Cambridge Group
`involving nickel titanium materials?
` MR. BAPNA: Objection, form.
`BY MR. DAHLGREN:
` Q Is that fair?
` A I'm sorry. Can you repeat the
`question?
` Q I asked is that fair. I'll say it one
`more time.
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` A. Kozak
` You don't recall any personal
`involvement in testing at the Cambridge Group
`involving nickel titanium materials; correct?
` A That's correct.
` Q Prior to your position as a research
`scientist at the Cambridge Group, what was your
`occupation?
` A So prior to working at the Cambridge
`Polymer Group I worked at a company called
`Cambridge Isotope Laboratories.
` Q And what was your position there?
` A There I was quality control
`technician.
` Q Sorry, what was the name of the
`company?
` A Cambridge Isotope Laboratories.
` Q And what were your job
`responsibilities as a quality control technician?
` A I was responsible for the chemical
`analysis of products produced by that company.
` Q And what type of products did they
`produce?
` A They produced isotopically labeled
`organic compounds. For example, isotopically
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`Page 13
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` A. Kozak
`labeled amino acids.
` Q Anything else?
` A Really a variety of products that fall
`under the umbrella of chemicals that are labeled
`with stable isotopes. That would also include,
`for example, labeled water. So deuterated water,
`for example. As well as other organic compounds.
`So for example, labeled organic solvents that are
`used for either production or diagnostic
`purposes.
` Q Did you do any work with metals while
`you were at the Cambridge Isotope Laboratory?
` A I did not.
` Q You mentioned previously that you've
`worked with some metals that are common in
`orthopedics and medical devices.
` Can you tell me what kind of
`orthopedic products that you've worked with while
`you've been at the Cambridge Polymer Group?
` A Sure. So I've worked on, for example,
`hip and knee implants.
` Q Anything else?
` A Those would be the primary products
`that we have been involved with.
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`Page 14
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` A. Kozak
` Q Okay. And you also mentioned medical
`devices.
` Can you tell me what medical devices
`you worked on, to the best of your recollection?
` A Sure. So we work with clients that
`produce a variety of devices, which includes
`things like catheters, stents, tissue scaffolds,
`for example.
` Q Have you worked on any other dental
`products other than your involvement in this
`proceeding?
` A I have been at most only tangentially
`involved in testing dental products.
` Q What products were those that you were
`tangentially involved in?
` A To give you a full list I would need
`to go back and to review the projects that I've
`been even tangentially involved in. One that
`comes to mind here is a spacer that was being
`used for a dental application where we were
`evaluating the radiopacity of the device.
` Q And do you recall any other dental
`products right now that you were involved in in
`any degree while you've been at the Cambridge
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` A. Kozak
`Polymer Group?
` A I do not.
` Q You also mentioned chemical
`characterizations. What type of chemical
`characterizations do you do as part of your work
`at the Cambridge Polymer Group?
` A So primarily chromatography. Testing
`such as gas chromatography and liquid
`chromatography, for example, coupled to mass
`spectroscopy.
` Q And do you do any chemical
`characterizations of metal products as part of
`your work at the Cambridge Polymer Group?
` A Yes.
` Q Could you describe that for me,
`please?
` A So the type of work that we do would
`include things like cleanliness analysis of metal
`products. Looking at the residue that is present
`on the surface of a metal product and evaluating
`the chemical constituents that are present in
`that residue.
` Q Would that include looking at, like,
`oxide growth on the surface of some type of metal
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` A. Kozak
`product?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: Can you repeat the
` question?
`BY MR. DAHLGREN:
` Q Sure. These -- you mentioned that you
`would look at residue present on the surface of a
`metal product. My question was, would those
`analyses include looking at oxide formation on
`the surface of a metal product?
` MR. BAPNA: Objection. Scope,
` relevance.
` THE WITNESS: I have not
` personally performed that testing. That
` testing has been done by Cambridge Polymer
` Group.
`BY MR. DAHLGREN:
` Q And we touched on this before, the
`mechanical characterizations.
` Could you -- and I apologize if we
`went over this, but could you tell me again what
`type of mechanical tests that you perform on
`products as part of your duties -- your job at
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` A. Kozak
`Cambridge Polymer Group?
` A So mechanical tests may include --
`there's a wide range of mechanical tests that are
`done at Cambridge Polymer Group and that I have
`been involved in. To give you an exhaustive
`list -- it would be a pretty long list. But for
`example, tensile testing, compression testing,
`bending testing -- or flexural testing, in other
`words -- dynamic mechanical analysis, biaxial
`testing, to name a few.
` Q Okay. Any others that you recall?
` A Burst testing, small punch testing,
`sheer testing rheology.
` Q And is small punch a type of hardness
`testing?
` A The results that you get are related
`to hardness. It's not a direct measure of
`hardness. It is a test that probes the biaxial
`deformation of a very thin specimen that's been
`taken usually from a finished device.
` Q Okay. So you would characterize your
`experience with mechanical tests as pretty --
`would you say exhaustive? It sounds like you've
`done a lot of tests.
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`Page 18
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` A. Kozak
` A I would say that I've spent a lot of
`time performing mechanical testing. I'm very
`familiar, comfortable with it.
` Q Okay. Have you ever done any
`differential scanning calorimetry testing?
` MR. BAPNA: Objection. Scope,
` relevance.
` THE WITNESS: Yes.
`BY MR. DAHLGREN:
` Q Is it all right if I refer to that as
`DSC?
` A Yes.
` Q Thank you.
` Can you tell me about the DSC testing
`that you've done?
` MR. BAPNA: Objection. Scope,
` relevance.
` THE WITNESS: Can you specify a
` context? DSC testing kind of comprises --
`BY MR. DAHLGREN:
` Q Sure. What materials have you
`performed DSC testing on?
` MR. BAPNA: Objection, scope,
` relevance.
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` A. Kozak
` THE WITNESS: So I've performed
` DSC testing primarily on polymeric materials
` as well as on wax materials. And those are
` the ones that I recall at the moment. There
` may be other categories of materials that
` I've also done testing on.
`BY MR. DAHLGREN:
` Q Have you done any DSC testing on
`metals?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: I have not.
`BY MR. DAHLGREN:
` Q Are you familiar with how DSC testing
`is conducted on metals?
` A I'm not aware of differences between
`the way a metal would be analyzed by DSC compared
`to the way, for example, a polymer would be
`analyzed by DSC.
` Q What type of information does DSC
`testing provide?
` MR. BAPNA: Objection. Scope,
` relevance.
` THE WITNESS: DSC testing
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` A. Kozak
` typically provides information on thermal
` transitions in a material. Things like a
` glass transition temperature or a melting
` point.
`BY MR. DAHLGREN:
` Q Are you familiar with the term
`"austenite"?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: I'm not.
`BY MR. DAHLGREN:
` Q Have you ever heard of austenite
`finish temperature?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: No.
`BY MR. DAHLGREN:
` Q Are you familiar with the term
`"martensite"?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: No.
`BY MR. DAHLGREN:
` Q So I think before you said that you
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` A. Kozak
`have not done any testing related to nickel
`titanium other than what you did in this current
`proceeding; is that right?
` A To the best of my knowledge, I have
`not been directly involved in testing of nickel
`titanium materials before this.
` Q Have you been indirectly involved in
`any testing of nickel titanium?
` A I would need to check because
`oftentimes, for example, if we're doing something
`like a chemical analysis, the residue that is
`submitted to us may have come from a device --
`may have come from an original product that
`either was nickel titanium or was -- had a
`component that was nickel titanium. So to
`accurately and clearly answer your question, I
`would need to look back at all the projects I was
`involved in. But to my knowledge, I'm not aware
`of another project that involved nickel titanium
`before the work that was done for Kenyon &
`Kenyon.
`BY MR. DAHLGREN:
` Q Okay. Have you ever done any thermal
`treatments on materials as part of your work for
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` A. Kozak
`the Cambridge Polymer Group?
` MR. BAPNA: Objection, form,
` relevance, scope.
` THE WITNESS: Can you specify what
` you mean by thermal treatment?
`BY MR. DAHLGREN:
` Q Do you have an understanding of the
`term "thermal treatment"?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: I have an
` understanding.
`BY MR. DAHLGREN:
` Q What's that understanding?
` MR. BAPNA: Same objections.
` THE WITNESS: My understanding of
` thermal treatment is exposing a material or
` device to a known controlled temperature for
` a period of time in a known atmosphere.
`BY MR. DAHLGREN:
` Q And using that definition, have you
`performed any heat treatments on materials as
`part of your work at the Cambridge Polymer Group?
` MR. BAPNA: Objection, scope,
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` A. Kozak
` relevance.
` THE WITNESS: Using that
` definition, yes. In the context of
` accelerated aging of materials.
`BY MR. DAHLGREN:
` Q What materials have you performed heat
`treatments on for accelerated aging?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: Primarily polymeric
` materials.
`BY MR. DAHLGREN:
` Q Any non-polymeric materials that
`you've used heat treatments for accelerated
`aging?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: Not to my knowledge.
`BY MR. DAHLGREN:
` Q Can you describe to me what you mean
`by accelerated aging?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: Accelerated aging is
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` A. Kozak
` a technique that's used to model what
` happens to material over time. So often an
` individual may be interested in knowing how
` properties of the device or material change,
` for example, after two years on the shelf.
` In order to get an idea for what those
` properties may be, someone may do an
` accelerated aging experiment in which those
` devices are placed in elevated temperature
` and maybe in a different environment. And
` that mimics the type of changes in the
` material that would be expected over a long
` period of time under less aggressive
` conditions.
`BY MR. DAHLGREN:
` Q Okay. Have you ever conducted any
`coating processes on materials?
` MR. BAPNA: Objection, scope,
` relevance, form.
` THE WITNESS: Yes.
`BY MR. DAHLGREN:
` Q And what coating processes have you
`used during your work at Cambridge Polymer Group?
` MR. BAPNA: Objection, scope,
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` A. Kozak
` relevance.
` THE WITNESS: Dip coating,
` primarily.
`BY MR. DAHLGREN:
` Q Do you recall any others?
` A No.
` Q Have you ever done any physical vapor
`deposition?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: No.
`BY MR. DAHLGREN:
` Q Chemical vapor deposition, have you
`ever done that?
` MR. BAPNA: Same objections.
` THE WITNESS: No.
`BY MR. DAHLGREN:
` Q Okay. So prior to your employment at
`the Cambridge Isotope Laboratory, did you have
`any other job?
` A Yes.
` Q And what was that?
` A I worked as a researcher in several
`laboratories.
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` A. Kozak
` Q And what were you researching during
`that time?
` A I was researching different topics at
`different laboratories. Would you like me to
`describe them?
` Q Just a brief summary of, yeah, what
`you were doing.
` A Sure. Sure. So I've spent time doing
`research in development of devices for pain
`monitoring, specifically in neonatal infants.
`I've spent time doing research for techniques and
`looking at the mechanisms of blood clotting,
`specifically in microfluidic devices. And I've
`spent time looking at the properties of
`polymer-coated electrodes, electrical properties
`of polymer-coated electrodes.
` That's a summary.
` Q Okay. Okay, thank you.
` And prior to working in these
`laboratories, did you have any other occupation?
` A I worked -- yes. I worked at a
`company called Spectra Stable Isotopes, as a
`technician.
` Q And what were you working on at
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` A. Kozak
`Spectra Stable Isotopes?
` A I was working on the management of
`algae biomass. So essentially a harvesting of
`algae biomass.
` Q You weren't doing, while you were at
`Spectra Stable Isotopes, any tests on mechanical
`testing of metal products; is that fair?
` A No. No.
` Q Okay. And before your employment at
`Spectra Stable Isotopes, was there anywhere else
`you were working?
` A No.
` Q Could you please summarize your
`education for me?
` A So my degree is in biomedical
`engineering from the University of Rochester.
` Q And is that a bachelor's degree?
` A That's a Bachelor's of Science degree.
` Q And what year did you graduate?
` A 2011.
` Q And after graduation, you said you've
`been at Cambridge Polymer Group for approximately
`four years; is that correct?
` A Uh-huh.
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` A. Kozak
` Q Okay. Did you take any material
`science courses while you were earning your
`degree from the University of Rochester?
` A There was -- there was a biomaterials
`course optional on the curriculum that I did not
`take.
` Q Okay. Have you heard of nickel
`titanium or had you heard of nickel titanium
`alloys before your involvement in this
`proceeding?
` A I had heard of them.
` Q Had you heard the term
`"superelasticity"?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: I've only
` tangentially heard the term.
`BY MR. DAHLGREN:
` Q Do you understand what the term
`"superelasticity" means?
` MR. BAPNA: Objection, scope,
` relevance.
`BY MR. DAHLGREN:
` Q Let me rephrase.
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` A. Kozak
` Do you have an understanding of the
`term "superelasticity"?
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: I don't feel
` comfortable giving you an accurate
` definition of what that means.
`BY MR. DAHLGREN:
` Q The question was do you have an
`understanding of what the term "superelasticity"
`means.
` MR. BAPNA: Objection, scope,
` relevance.
` THE WITNESS: No.
`BY MR. DAHLGREN:
` Q So you have no understanding of what
`the term "superelasticity" means?
` MR. BAPNA: Objection, form,
` scope, relevance.
` THE WITNESS: I've only heard the
` term, yeah.
`BY MR. DAHLGREN:
` Q What's your best understanding as to
`what superelasticity refers to?
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` MR. BAPNA: Objection, form,
` scope, relevance.
` THE WITNESS: I understand that
` the term is related to a -- it's a
` metallurgical term. I'm not a metallurgist.
` Again, I don't have a good
` understanding of what the term
` "superelasticity" means. Based on an
` understanding of mechanical properties of
` materials, I could only speculate as to what
` superelastic would mean relative to, let's
` say, an elastic property.
`BY MR. DAHLGREN:
` Q Again, my question is what's your best
`understanding of what it means. And I understand
`the caveats that you've given, but can you answer
`the question?
` MR. BAPNA: Objection, form,
` scope, relevance.
` THE WITNESS: To me, superelastic
` implies that a material has a very wide
` elastic range.
`BY MR. DAHLGREN:
` Q Okay. And before -- going back to the
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` A. Kozak
`heat treatment processes, you mentioned that you
`have done heat treatments on certain polymers; is
`that correct?
` MR. BAPNA: Objection.
` THE WITNESS: Yes.
`BY MR. DAHLGREN:
` Q Would you consider heating something
`at 25 degrees Celsius to be a heat treatment
`process?
` MR. BAPNA: Objection, form,
` scope, relevance.
` THE WITNESS: No. I would
` consider it to be a form of conditioning.
`BY MR. DAHLGREN:
` Q Okay. So you would agree when someone
`is referring to doing a heat treatment, you
`wouldn't immediately think that they're doing a
`heat treatment at 25 degrees Celsius; correct?
` MR. BAPNA: Objection. Form,
` scope, relevance.
` THE WITNESS: The way in which I
` understand heat treatments for the materials
` which I'm used to working with, of course,
` for a certain material, raising it to a
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` temperature of 25 degrees may be relevant
` for that material. But under the materials
` that I'm used to working with, I would not
` consider 25 degrees to be a heat treatment.
`BY MR. DAHLGR
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