Case 1:20-cv-00393-LMB-TCB Document 1416-1 Filed 08/19/22 Page 1 of 4 PageID# 35727
`Case 1:20-cv-00393-LMB-TCB Document 1416-1 Filed 08/19/22 Page 1 of 4 PagelD# 35727
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`EXHIBIT A
`EXHIBIT A
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`

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`Case 1:20-cv-00393-LMB-TCB Document 1416-1 Filed 08/19/22 Page 2 of 4 PageID# 35728
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`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 10:11:57 PM
`
`PMI v. RJR EDVa Trial
`
`Hunt, Eric (Vol. 01) - 11/16/2020
`1 CLIP (RUNNING 00:01:25.510)
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`Hunt,E_111620_ALL_TRIMMED2
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`10 SEGMENTS (RUNNING 00:01:25.510)
`EH-ALL-FINAL
`1. PAGE 12:17 TO 12:18 (RUNNING 00:00:08.661)
` 17 Q. And what is your current role at Reynolds?
` 18 A. I'm a senior manager in vapor product development.
`2. PAGE 21:11 TO 21:13 (RUNNING 00:00:15.194)
` 11 MR. WATSON: Yes. Let's mark -- so the
` 12 record is clear, Exhibit 3 is the document Bates
` 13 labeled RJRITC_001360053.
`3. PAGE 21:20 TO 22:01 (RUNNING 00:00:08.248)
` 20 Q. Okay. So, Mr. Hunt, let me try this again. This
` 21 document that I have on the screen here, Exhibit 3,
` 22 this is part of the Vuse Alto PMTA that Reynolds
` 00022:01 provides to the FDA?
`4. PAGE 22:02 TO 22:03 (RUNNING 00:00:06.255)
` 02 A. Yes, this appears to be Section H of the Vuse Alto
` 03 PMTA.
`5. PAGE 57:03 TO 57:06 (RUNNING 00:00:17.635)
` 03 Q. Okay. So the Vuse Alto device includes this reservoir
` 04 which holds the liquid formulation; is that right?
` 05 A. Yes, that is correct. There is -- there's a reservoir
` 06 for holding bulk liquid in the Vuse Alto cartridge.
`6. PAGE 59:02 TO 59:03 (RUNNING 00:00:04.514)
` 02 By the ceramic wick being porous, that
` 03 means it's permeable to liquid. Right?
`7. PAGE 59:04 TO 59:08 (RUNNING 00:00:15.791)
` 04 A. Yes. I would say, as long as the liquid -- as long as
` 05 the liquid has the correct properties to be permeable
` 06 within the -- within the pores created in the ceramic
` 07 body, yes.
` 08 Q. It would be permeable to gas?
`8. PAGE 59:11 TO 59:11 (RUNNING 00:00:03.096)
` 11 A. Yes, I would say it would be permeable to a gas.
`9. PAGE 68:04 TO 68:05 (RUNNING 00:00:05.017)
` 04 Q. So would the -- does the ceramic wick allow transport
` 05 of liquid across it?
`10. PAGE 68:08 TO 68:08 (RUNNING 00:00:01.099)
` 08 A. Yes, it does.
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`TOTAL: 1 CLIP FROM 1 DEPOSITION (RUNNING 00:01:25.510)
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`page 1
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`Case 1:20-cv-00393-LMB-TCB Document 1416-1 Filed 08/19/22 Page 3 of 4 PageID# 35729
`
`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 10:11:13 PM
`
`PMI v. RJR EDVa Trial
`
`Hunt, Vol. 2, Eric (Vol. 01) - 04/14/2021
`1 CLIP (RUNNING 00:03:39.443)
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`Hunt,E_041421_ALL_TRIMMED2
`
`14 SEGMENTS (RUNNING 00:03:39.443)
`EH-ALL2-FINAL
`1. PAGE 448:05 TO 448:06 (RUNNING 00:00:10.641)
` 05 MR. RAVULA: Can we pull up tab 44 on the
` 06 screen, and let's call this Exhibit, I think, 40.
`2. PAGE 448:16 TO 449:09 (RUNNING 00:01:04.445)
` 16 Q Are you able to see that on your screen,
` 17 Mr. Hunt?
` 18 A I am.
` 19 Q Okay. So this first page of Exhibit 40
` 20 shows a CAD image of the Vuse Alto mouthpiece
` 21 looking from the bottom. Is that a fair statement?
` 22 A Yeah, that's a fair statement. It's in
` 00449:01 wire mode, so it's kind of really hard to kind of
` 02 see. But, yeah, that's a fair statement.
` 03 Q The oval at the center is the exit hole
` 04 through which aerosol exits the mouthpiece to go
` 05 into the user's mouth, correct?
` 06 A Yes, that is correct.
` 07 Q Bordering the top of the oval exit hole is
` 08 a raised lip, right?
` 09 A Yes, that's correct.
`3. PAGE 450:18 TO 450:22 (RUNNING 00:00:16.958)
` 18 Q Can we turn to the next page, please.
` 19 This is a CAD image of the Vuse Alto
` 20 mouthpiece looking from the bottom with the spaces
` 21 between the raised lips and the inner wall of the
` 22 mouthpiece colored red.
`4. PAGE 451:01 TO 451:08 (RUNNING 00:00:27.669)
` 00451:01 Do you see that?
` 02 A I do.
` 03 Q If you were looking into the mouthpiece
` 04 from the view of a consumer using the Alto, you
` 05 wouldn't see that these spaces, correct?
` 06 A That is correct.
` 07 Q The spaces colored red are symmetric,
` 08 right?
`5. PAGE 451:10 TO 451:15 (RUNNING 00:00:18.121)
` 10 A Yes, I think they're symmetric as opposed
` 11 to both sides -- or to that side of the oval, or to
` 12 the oval in general, the long portion of the oval,
` 13 yes.
` 14 Q And they have the same dimensions, right?
` 15 A Yes.
`6. PAGE 451:16 TO 451:17 (RUNNING 00:00:05.725)
` 16 Q Can we pull up tab 45, which will be
` 17 Exhibit 41, please.
`7. PAGE 451:22 TO 452:01 (RUNNING 00:00:02.074)
` 22 Q Are you able to see that on your screen,
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`Case 1:20-cv-00393-LMB-TCB Document 1416-1 Filed 08/19/22 Page 4 of 4 PageID# 35730
`
`Case Clip(s) Detailed Report
`Tuesday, June 07, 2022, 10:11:13 PM
`
`PMI v. RJR EDVa Trial
`
` 00452:01 Mr. Hunt?
`8. PAGE 452:02 TO 452:08 (RUNNING 00:00:16.034)
` 02 A I am.
` 03 Q All right. So the first page of
` 04 Exhibit 41 has a CAD image showing a close-up of the
` 05 space between the upper raised lip and the inner
` 06 wall of the Alto mouthpiece with that space colored
` 07 red.
` 08 Do you see that?
`9. PAGE 452:10 TO 452:10 (RUNNING 00:00:01.034)
` 10 A I do.
`10. PAGE 456:17 TO 456:19 (RUNNING 00:00:08.115)
` 17 Q Sure. You agree that condensate could
` 18 form in the area between the raised lip and the
` 19 inner wall of the mouthpiece of the Alto, correct?
`11. PAGE 456:20 TO 456:21 (RUNNING 00:00:06.632)
` 20 A I agree that a portion of that space,
` 21 condensate could form on the seal.
`12. PAGE 457:14 TO 457:19 (RUNNING 00:00:18.868)
` 14 Q And you have no reason to doubt that the
` 15 distance between the top left of the outer wall of
` 16 the raised lip and the inner wall of the mouthpiece
` 17 is approximately 0.92 millimeters, right?
` 18 A That's correct. I don't have any reason
` 19 to doubt that that's approximately the length.
`13. PAGE 460:02 TO 460:05 (RUNNING 00:00:08.649)
` 02 Q Reynolds has not made any changes to the
` 03 design of the cartridges of the accused products
` 04 since October 2018, right?
` 05 A Yes, that's correct.
`14. PAGE 460:11 TO 460:14 (RUNNING 00:00:14.478)
` 11 Q And Reynolds does not have any current
` 12 plans to change the design of the cartridges of the
` 13 accused products, correct?
` 14 A That is also correct -- statement.
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`TOTAL: 1 CLIP FROM 1 DEPOSITION (RUNNING 00:03:39.443)
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`page 2
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