`Case 1:17-cv-00770-JDW Document 369-18 Filed 04/12/24 Page 1 of 3 PagelD #: 33696
`
`EXHIBIT 18
`EXHIBIT 18
`
`
`
`Case 1:17-cv-00770-JDW Document 369-18 Filed 04/12/24 Page 2 of 3 PageID #: 33697
`
`1/12/2024
`
`Wirtgen America Inc. v. Caterpillar Inc.
`
`Garrett Montle
`
`Page 1
`
` IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE
`___________________________
`WIRTGEN AMERICA, INC., )
` Plaintiff, )
` -vs- ) Case No.
`CATERPILLAR, INC., ) 1:17-cv-00770-JDW-MPT
` Defendant. )
`___________________________)
`
` VIDEOTAPED DEPOSITION
` TAKEN REMOTELY VIA VIDEOCONFERENCE OF
` GARRETT MONTLE
` 1600 DIVISION STREET - SUITE 500
` NASHVILLE, TENNESSEE 37203
` JANUARY 12, 2024
` 8:58 A.M. CST
`
` REPORTED BY:
` DEBRA SAPIO LYONS, RDR, CRR, CRC, CCR, CLR, CPE
`______________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
` (202) 232-0646
`
`www.DigitalEvidenceGroup.com Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`
`
`Case 1:17-cv-00770-JDW Document 369-18 Filed 04/12/24 Page 3 of 3 PageID #: 33698
`
`1/12/2024
`
`Wirtgen America Inc. v. Caterpillar Inc.
`
`Garrett Montle
`
`Page 34
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` the '530 Patent?
` MR. YONAN: Objection, speculation.
` THE WITNESS: I am not aware.
` BY MR. SMITH:
` Q. And focusing on Claim 1 of the
` '530 Patent, are you aware of any reason why
` Wirtgen could not have presented Claim 1 of the
` '530 Patent in one of the two earlier
` continuations?
` MR. YONAN: Objection; foundation,
` speculation.
` THE WITNESS: I'm not aware.
` BY MR. SMITH:
` Q. And do you understand that Wirtgen --
` let's go to the top of -- strike that.
` If you could look at the top of Page 1
` of McKinney Exhibit 16, please.
` A. 16.
` Q. And do you see that the patent
` initially was applied for by Wirtgen GmbH?
` A. Yes, my apologies. I'm still --
` Q. Okay.
`
`www.DigitalEvidenceGroup.com Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`
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