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`C.P . CHRISTENSEN
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`Page 1
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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE SOUTHERN DISTRICT OF NEW YORK
`
`CERT~
`vO
`
`D
`
`Civil Action
`
`No. 06 CV 4005
`(TPG) (GWG)
`
`Plaintiff,
`
`vs.
`
`LAZARE KAPLAN INTERNATIONAL,
`INC.,
`
`)
`)
`)
`)
`)
`)
`)
`)
`GEMOLOGICAL INSTITUTE OF AMERICA,)
`a California Corporation, et al.,)
`)
`)
`Defendants.
`~~~~~~~~~~~~~~~~~->
`
`VIDEOTAPED DEPOSITION OF C. PAUL CHRISTENSEN
`
`Washington, D.C.
`
`Tuesday, July 12, 2011
`
`Reported .by :
`
`John L. Harmonson, RPR
`
`Job No . 39388
`
`TSG Reporting - Worldwide
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`877-702-9580
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`IPR2015-00024
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`Lazare Kaplan International, Inc. Exhibit 2011 Page 1
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`C.P . CHRISTENSEN
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`Page 1
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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE SOUTHERN DISTRICT OF NEW YORK
`
`CERT~
`vO
`
`D
`
`Civil Action
`
`No. 06 CV 4005
`(TPG) (GWG)
`
`Plaintiff,
`
`vs.
`
`LAZARE KAPLAN INTERNATIONAL,
`INC.,
`
`)
`)
`)
`)
`)
`)
`)
`)
`GEMOLOGICAL INSTITUTE OF AMERICA,)
`a California Corporation, et al.,)
`)
`)
`Defendants.
`~~~~~~~~~~~~~~~~~->
`
`VIDEOTAPED DEPOSITION OF C. PAUL CHRISTENSEN
`
`Washington, D.C.
`
`Tuesday, July 12, 2011
`
`Reported .by :
`
`John L. Harmonson, RPR
`
`Job No . 39388
`
`TSG Reporting - Worldwide
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`877-702-9580
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`IPR2015-00024
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`Lazare Kaplan International, Inc. Exhibit 2011 Page 1
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`C.P. CHRISTENSEN
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`July 12, 2011
`
`10:29 a.m.
`
`Videotaped Deposition of C. PAUL
`
`CHRISTENSEN, held at the offices of DLA Piper US,
`
`LLP, 500 Eighth Street, N.W., Washington, D.C.,
`
`pursuant to subpoena, before John L. Harmonson, a
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`13 Registered Professional Reporter and Notary
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`Public of the District of Columbia.
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`1
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`C.P. CHRISTENSEN
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`2 AP P EAR AN C E S:
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`MORRISON & FOERSTER
`
`Attorneys for Plaintiff
`
`1290 Avenue of the Americas
`
`New York, New York 10104
`
`BY:
`
`JAMES E. HOUGH, ESQ.
`
`DLA PIPER
`
`Attorneys for Defendant GIA
`
`401 B Street
`
`Suite 1700
`
`San Diego, California 92101
`
`BY:
`
`JOHN D. KINTON, ESQ.
`
`ALSO PRESENT:
`
`MIA MARBURY, VIDEOGRAPHER
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`TSG Reporting - Worldwide
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`C.P. CHRISTENSEN
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`P R 0 C E E D I N G S
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`THE VIDEOGRAPHER: Good morning. This
`
`is the start of the tape labeled No. 1,
`
`Volume 2, of the videotaped deposition of
`
`Dr. C. Paul Christensen, taken in the matter
`
`of Lazare Kaplan International, Inc. v.
`
`PhotoScribe Technologies, Inc., a New York
`
`Corporation, Gemological Institute of
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`10 America, a California corporation, and David
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`11 Benderly, in the United States District
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`Court for the Southern District of New York,
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`Case No. 06 CV 4005.
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`This deposition is being held at DLA
`
`Piper at 500 Eighth Street, N.W.,
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`16 Washington, D.C., 20004.
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`Today's date is July 12, 2011. The
`
`time on the video screen is 10:29:53.
`
`My name is Mia Marbury from TSG
`
`Reporting, Inc. and I am the legal video
`
`specialist. The court reporter today is
`
`John Harmonson in association with TSG
`
`Reporting.
`
`Will counsel please introduce
`
`yourselves.
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`C.P. CHRISTENSEN
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`MR. HOUGH:
`
`I'm Jim Hough from
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`Morrison Foerster representing the
`
`plaintiff.
`
`MR. KINTON:
`
`I'm John Kinton from DLA
`
`Piper representing the defendants.
`
`THE VIDEOGRAPHER: Thank you,
`
`gentlemen.
`
`Will the court reporter please swear
`
`in the witness after which we can begin.
`
`C. PAUL CHRISTENSEN,
`
`after having been first duly sworn, was examined
`
`and did testify under oath as follows:
`
`EXAMINATION
`
`BY MR. KINTON:
`
`Q.
`
`A.
`
`Q.
`
`Good morning, Dr. Christensen.
`
`Good morning.
`
`Would you please state your name and
`
`address for the record?
`
`A.
`
`Yes. My name is Paul Christensen. My
`
`full name is Clyde Paul Christensen, Jr.
`
`I live
`
`at 231 Hidden Valley Road in Tracys Landing,
`
`24 Maryland. And the zip there is 20779.
`
`Q.
`
`And did you understand the oath that
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`TSG Reporting - Worldwide
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`C.P. CHRISTENSEN
`
`you just took?
`
`A.
`
`Q.
`
`I do.
`
`And you understand that you're
`
`required to give truthful answers to my questions
`
`today?
`
`A.
`
`Q.
`
`I understand.
`
`And is there any reason that you can't
`
`give me truthful answers today?
`
`A.
`
`Q.
`
`Not that I know of.
`
`You're not on any medication, you
`
`don't have any medical conditions that would
`
`prevent you from giving me truthful answers?
`
`A.
`
`Q.
`
`No.
`
`You're doing a good job of it so far,
`
`but I would ask that you wait until I finish my
`
`question before answering because the court
`
`reporter is taking down every word we say.
`
`Will you do ·that for me?
`
`Sure.
`
`And if you don't understand a question
`
`A.
`
`Q.
`
`I ask you, will you let me know?
`
`A.
`
`Q.
`
`Of course.
`
`I understand that you've already been
`
`deposed in this case.
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`·;
`.··
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`..
`...
`..
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`i
`.
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`I
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`I.
`I.,
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`.
`
`I<
`H
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`.. ·
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`. ..
`.
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`Lazare Kaplan International, Inc. Exhibit 2011 Page 6
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`C.P. CHRISTENSEN
`
`I have, uh-huh.
`
`So the procedure is going to be very
`
`A.
`
`Q.
`
`similar.
`
`Just as last time, if you need a break
`
`at any time, please let me know.
`
`Will you do that for me?
`
`Sure.
`
`The one -- The one request that I have
`
`A.
`
`Q.
`
`is if you do ask for a break, that you not do it
`
`while a question is pending.
`
`Will you do that for me?
`
`A.
`
`Sure.
`
`MR. KINTON:
`
`I would like to hand
`
`you -- or have the court reporter mark as
`
`Defendants' Exhibit 373 a document titled
`
`United States -- or "Subpoena to Testify at
`
`the- Deposition in a Civil Action."
`
`(Exhibit 373 marked for identification
`
`and attached hereto.)
`
`Q.
`
`Dr. Christensen, I would like you to
`
`look at Exhibit 373 for the purpose of
`
`determining whether you recognize it or not, and
`
`let me know when you've had a chance to do that.
`
`A.
`
`Yes, I recognize it. This looks like
`
`the one I received.
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`Q.
`
`A.
`
`by e-mail.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`C.P. CHRISTENSEN
`
`And how did you come to receive that?
`
`This was sent to me with my agreement
`
`By e-mail?
`
`Yes.
`
`With your agreement?
`
`With my agreement, uh-huh.
`
`And as we mentioned earlier, you were
`
`previously deposed in this case; is that right?
`
`A.
`
`Q.
`
`That's correct.
`
`I'm going to ask the court reporter to
`
`13 mark as Defendants' Exhibit 374 the deposition
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`transcript of Paul Christensen.
`
`(Exhibit 374 marked for identification
`
`and attached hereto.)
`
`Q.
`
`Dr. Christensen, are you aware of
`
`anything, any testimony that you provided in your
`
`first deposition that you would like to correct
`
`as you sit here today?
`
`A.
`
`No, I'm not.
`
`I haven't reviewed it
`
`carefully, but I don't have anything that comes
`
`to mind.
`
`Q.
`
`Okay.
`
`I believe in your first
`
`deposition you testified that you were a
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`C.P. CHRISTENSEN
`
`consultant for Potomac Photonics; is that right?
`
`A.
`
`Q.
`
`That's correct.
`
`Has your relationship with Potomac
`
`Photonics stayed the same since your deposition
`
`or has it changed?
`
`A.
`
`It's essentially the same.
`
`I still am
`
`working with them on a consulting basis.
`
`I also
`
`have a contract, or a grant rather, that's run
`
`through Potomac from the National Science
`
`Foundation to do some development work. And for
`
`that particular piece of work, I'm a part-time
`
`employee for Potomac. So that's -- that's
`
`basically the situation there.
`
`I also have started a company called
`
`Potomac Vessel Systems and we do some work with
`
`Potomac on contract. So there's two or three
`
`ways that I'm connected with Potomac Photonics.
`
`Q.
`
`Have you had any dealings with Lazare
`
`Kaplan since you were last deposed?
`
`A.
`
`No.
`
`I had I think an e-mail from
`
`George Kaplan which I didn't respond to a couple
`
`of years ago, as I recall. But that's about the
`
`extent of it.
`
`Q.
`
`At your first deposition you were
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`C.P. CHRISTENSEN
`
`questioned regarding some laser machine tools
`
`that were developed by Potomac Photonics in the
`
`early 1990s.
`
`Do you recall that generally?
`
`Generally, yes, uh-huh.
`
`And I believe there were several laser
`
`A.
`
`Q.
`
`machine tools discussed. There was the LMT-1000,
`
`the LMT-2000, the LMT-4000 and there was also a
`
`discussion of a machine on a lab table that was
`
`set up to be flexible in the sense that you could
`
`change components out.
`
`Is that right?
`
`A.
`
`That sounds -- That sounds right,
`
`yeah.
`
`Q.
`
`Any other laser inscription machines
`
`that you recall being developed by Potomac
`
`Photonics in the early '90s?
`
`A.
`
`In the early '90s, no. We did several
`
`sorts of R&D special one-off type things,
`
`breadboard type equipment that we built for
`
`different people. But those were our -- We tried
`
`to have a more or less standard offering, and it
`
`evolved from the LMT-1000 up through the 4000.
`
`So those are our standard products, more or less
`
`standard products.
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`C.P. CHRISTENSEN
`
`Q.
`
`So I'm looking for a label that we can
`
`use throughout today to ref er to the machine on
`
`the lab table as we go along.
`
`Would it be fair to call that the
`
`Potomac Photonics lab table machine?
`
`A.
`
`Sure.
`
`MR. HOUGH: Objection to form.
`
`When I make an objection like that,
`
`it's just for the record and you can go
`
`ahead and answer the question.
`
`THE WITNESS: Okay.
`
`It's okay to use that label?
`
`That would be understandable to me.
`
`And I believe you testified that all
`
`Q.
`
`A.
`
`Q.
`
`of these machines, the LMT-1000, the LMT-2000,
`
`the LMT-4000 and the Potomac Photonics lab table
`
`18 machine all operated similarly.
`
`Is that correct?
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`A.
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`Yeah. Generally we had the same kind
`
`of layout, yeah. There were some small
`
`variations in terms of which specific laser might
`
`go into it or how we might monitor the laser
`
`energy or the software, those kinds of things.
`
`But that was -- they were basically all the same
`
`general concept in terms of the laser, beam
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`delivery system, those sorts of things.
`
`Q.
`
`Okay.
`
`I'm going to hand you a series
`
`of exhibits that were previously marked at your
`
`first deposition. These are going to be
`
`6 Defendants' Exhibit 212, Exhibit 214, Exhibit
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`215, Exhibit 216 and Exhibit 218.
`
`Dr. Christensen, the Exhibit 212,
`
`Exhibit 214, Exhibit 215, Exhibit 216, Exhibit
`
`217 and Exhibit 218 are a series of articles that
`
`you authored or co-authored in the 1992 to 1994
`
`time frame; is that right?
`
`A.
`
`I believe that's correct.
`
`I think
`
`that time frame is spot on.
`
`Q.
`
`Okay.
`
`I would like to direct your
`
`attention initially to Exhibit 212 for me, and
`
`have you take a look at page 130. There's a
`
`Figure 4 on that page.
`
`A.
`
`Q.
`
`Okay.
`
`And hold that page open, and then also
`
`turn to the first page of the article.
`
`A.
`
`Q.
`
`Okay.
`
`And in the abstract it says:
`
`"Using a
`
`tabletop microfabrication system that integrates
`
`a waveguide excimer laser with vision and motion
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`C.P. CHRISTENSEN
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`control systems, we have generated
`
`three-dimensional structures through direct-write
`
`photoablation of polyimide substrates."
`
`Do you see that?
`
`Uh-huh.
`
`And then turn to Figure 4 on page 130
`
`A.
`
`Q.
`
`of Exhibit 212.
`
`A.
`
`Q.
`
`Uh-huh.
`
`Is that a schematic of the tabletop
`
`11 microfabrication system that's referred to in the
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`abstract?
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`A.
`
`Q.
`
`Yes, it is, uh-huh.
`
`And is the tabletop microfabrication
`
`system the Potomac Photonics lab table machine?
`
`A.
`
`It would be -- We had several, but
`
`it -- Yeah, it would be that sort of machine,
`
`uh-huh.
`
`Q.
`
`Was it the LMT-1000 or was it a lab
`
`table machine?
`
`A.
`
`Most of this work that was done
`
`in-house we did not necessarily on the full setup
`
`that went along with the LMT series. We had the
`
`basic essential parts of that on so-called
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`optical breadboards that we could easily change
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`and adjust things. And this was more than likely
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`done on that.
`
`Q.
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`A.
`
`Okay.
`
`But this is basically the layout that
`
`we would have used for that.
`
`Q.
`
`Okay.
`
`I would like to direct your
`
`attention to Defendants' Exhibit 214 for me.
`
`Exhibit 214.
`
`If you look at page 15 of Exhibit
`
`214 1 which is actually the second page of the·
`
`exhibit 1
`
`there is another figure 1 Figure 1.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Yes.
`
`Do you see that?
`
`Uh-huh.
`
`And is that the equipment
`
`configuration -- or is the equipment
`
`configuration there the same as the equipment
`
`configuration that was used in the LMT-1000 1
`
`LMT-2000 1 LMT-4000 and the Potomac Photonics lab
`
`table machine?
`
`MR. HOUGH: Objection to form.
`
`But you may answer.
`
`A.
`
`Yeah 1 it's basically it. It calls out
`
`here a UV waveguide laser 1 and on some of those
`
`systems and applications we used a different kind
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`of laser. But the rest of it is essentially the
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`same.
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`Q.
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`So on the Potomac Photonics lab table
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`5 machine, you could swap out the types of lasers?
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`A.
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`Q.
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`Yes, we could.
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`But the other components were
`
`essentially the same?
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`A.
`
`Yeah, basically. We might have to
`
`change, for example, specific lenses or mirrors
`
`so that they were operating at the right
`
`12 wavelength or focused or defocused properly. But
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`13
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`14
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`15
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`16
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`the basic configuration, this is very typical the
`
`way we set up our equipment.
`
`Q.
`
`You can set that exhibit aside.
`
`I would like to turn your attention to
`
`17 Defendants' Exhibit 216, which is the fine
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`diamonds with laser machining article.
`
`A.
`
`Q.
`
`Okay.
`
`And again, if you turn to the second
`
`page of that article there is a very similar
`
`figure.
`
`A.
`
`Q.
`
`Uh-huh.
`
`And is that the configuration of the
`
`Potomac Photonics lab table machine that was used
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`to perform
`
`the
`
`work described in this paper?
`
`MR.
`
`HOUGH: Objection to form.
`
`But
`
`you may answer.
`
`A.
`
`Yes.
`
`This is the basic kind of
`
`configuration we would have used, uh-huh.
`
`Q.
`
`And was that the configuration that
`
`was in fact used?
`
`A.
`
`As far as I know. As far as I can
`
`remember, let me put it that way.
`
`Q.
`
`And this article was published in
`
`1993; is that right?
`
`A.
`
`Q.
`
`That's what it says, yeah.
`
`And so that configuration was used at
`
`Potomac Photonics in at least the 1993 time
`
`frame; is that right?
`
`-A.
`
`I'm sure it was, yeah. Yeah, we
`
`pretty much used that same configuration from
`
`nearly the very beginning of our work with
`
`20 micromachining.
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`21
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`Q.
`
`And was the LMT-1000 in use at Potomac
`
`Photonics before 1994?
`
`A.
`
`I don't -- I don't recall. The
`
`LMT-1000 was something that we, as I say, it
`
`was -- it was set up to a deliverable product to
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`C.P. CHRISTENSEN
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`a customer. And the innards of that, the
`
`components of that were in use from very early
`
`days of micromach~ning.
`
`So I guess the answer to that would be
`
`it wasn't like you would come in and see an
`
`LMT-1000 sitting there, but you would see all of
`
`the key elements on one or more benches being
`
`used. So ...
`
`Q.
`
`Was an LMT-1000 actually sold to a
`
`customer before the LMT-4000 was developed?
`
`A.
`
`I'm pretty sure it was.
`
`I don't
`
`remember the exact dates and sales figures, but
`
`I'm almost certain it was, yes.
`
`Q.
`
`Was it on sale before the LMT-4000 was
`
`developed?
`
`A.
`
`Q.
`
`It was, yeah.
`
`And was the LMT-2000 on sale before
`
`the LMT-4.000 was developed?
`
`A.
`
`It would have been.
`
`It was sort of an
`
`evolution in that series and the higher numbers
`
`tended to be the later ones.
`
`Q.
`
`I'm going to hand you what was
`
`previously marked as Defendants' Exhibit 219.
`
`I
`
`would like you to turn to the second page.
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`Page 18
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`C.P. CHRISTENSEN
`
`Well, first of all, let's turn back to
`
`the first page. Defendants' Exhibit 219
`
`indicates that it was published in January of
`
`1995.
`
`A.
`
`Q.
`
`Do you see that?
`
`Yes, I see that. Uh-huh.
`
`Is that commensurate with your
`
`recollection as to when this article was
`
`published?
`
`A.
`
`Q.
`
`That sounds about right, uh-huh.
`
`And if you look at the second page of
`
`Exhibit 219, there is an advertisement for the
`
`laser micromachining station LMT-4000.
`
`Do you see that?
`
`I see it, uh-huh.
`
`And does that indicate to you whether
`
`A.
`
`Q.
`
`or not the LMT-4000 was on sale before January of
`
`1995 or not?
`
`A.
`
`Yes, it would have been. This was
`
`I guess the question is what is on sale. But
`
`would we have sold something like that? Yes.
`
`And this was obviously built before that time
`
`frame.
`
`This is a marketing picture, and it
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`was taken of a real machine to -- we made that to
`
`put it on sale. So generally you had to get
`
`your -- I'm just going from the sequence here.
`
`We had to have that picture
`
`substantially before this article was published
`
`by this date. And how far before 1
`
`I don't know.
`
`But we had obviously built something several
`
`9 months before that. But the exact time frame 1
`
`I
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`10
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`11
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`12
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`don't know.
`
`Q.
`
`Okay. So is it fair to say 1
`
`then 1
`
`that the LMT-1000 1
`
`the LMT-2000 and the LMT-4000
`
`13 were all at least on sale before January of 1995?
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`MR. HOUGH: Objection to form.
`
`Go ahead.
`
`Yes 1 it is. Uh-huh 1 yes.
`
`And is it fair to say that the Potomac
`
`A.
`
`Q.
`
`Photonics lab table machine was in use in the
`
`United States before January 1995?
`
`A.
`
`Q.
`
`Absolutely 1 yeah.
`
`And were technology concepts proven on
`
`the Potomac Photonics lab table machine before
`
`they were commercialized in the Potomac Photonics
`
`products?
`
`MR. HOUGH: Objection to form.
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`A.
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`Yes, they were. Typically they were,
`
`uh-huh.
`
`Q.
`
`Now, at your first deposition you
`
`testified that you inscribed diamonds for Lazare
`
`6 Kaplan.
`
`Is that correct?
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`Q.
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`We did.
`
`And was that also in the 1992 to 1994
`
`time frame?
`
`A.
`
`I don't remember exactly, but it was
`
`approximately that, yes.
`
`Q.
`
`You testified that you inscribed caps
`
`cut off of the flat part of the diamond, and that
`
`after that you did -- after you did the test cap
`
`15 marking you also had gemstones to inscribe;, is
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`that right?
`
`A.
`
`Q.
`
`That's correct, uh-huh.
`
`If you look in Defendants'
`
`Exhibit 216, which is the fine diamonds article,
`
`on page 108, Figure 4.
`
`Figure 4 says that the butterflies
`
`inscribed in, quote, a polished diamond surface,
`
`close quote.
`
`Is that right?
`
`A.
`
`Q.
`
`That's correct, uh-huh.
`
`Do you recall where you got that
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`polished diamond surf ace?
`
`A.
`
`Most of this material we got as test
`
`4 material from Lazare Kaplan as these end caps
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`from cut gemstones.
`
`Q.
`
`And so it's your understanding that
`
`the end caps were pieces of diamond gemstones; is
`
`that right?
`
`A.
`
`Yes. As I understand it, we -- and
`
`I'm not exactly sure how these are produced.
`
`I
`
`think on this Figure 3 you can see it's sort of a
`
`cylindrical structure there. We had several
`
`pieces like this which I understood had come from
`
`cutting and polishing of gemstones.
`
`Q.
`
`So because Exhibit 216 was published
`
`in 1993, is it fair to say that Potomac Photonics
`
`inscribed diamond gemstones for Lazare Kaplan
`
`before January of 1995?
`
`A.
`
`Q.
`
`Yes, I think that's fair.
`
`And was the -- it was the Potomac
`
`Photonics lab table machine that was used to
`
`inscribe those diamond gemstones?
`
`A.
`
`Q.
`
`It was, yeah. Uh-huh.
`
`And was Potomac Photonics paid to
`
`inscribe those diamond gemstones for Lazare
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`Kaplan?
`
`A.
`
`I don't recall, frankly. That's a
`
`good question. Because there was a lot of
`
`discussion at that time -- around that time about
`
`making equipment for Lazare Kaplan.
`
`Generally we didn't like to do a lot
`
`of work without some sort of payment, but I -- to
`
`tell the truth, I just don't know.
`
`I'm just not
`
`sure.
`
`Q.
`
`Do you have an understanding as to
`
`12 what the purpose of inscribing the diamond
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`gemstones for Lazare Kaplan was?
`
`MR. HOUGH: Objection to form.
`
`You may answer.
`
`A.
`
`Yes, I think so.
`
`It was for a means
`
`of identification and tracking, and it was
`
`intended to be something, I believe, that
`
`19 wouldn't affect the value of the diamond but
`
`20
`
`would allow it to be uniquely identified.
`
`It
`
`21 wouldn't detract from the value.
`
`I guess it
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`22
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`23
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`24
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`25
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`actually increased the value, if you could.~.
`
`Q.
`
`I guess my question -- the focus of my
`
`question may have been a little bit unclear. But.
`
`do you have any understanding as to why Lazare
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`'
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`ll
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`.:
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`Page 23
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`C.P. CHRISTENSEN
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`Kaplan wanted you to mark the diamond gemstones,
`
`or the gemstone pieces? For example, was it to
`
`demonstrate the capability?
`
`A.
`
`It was to demonstrate the --
`
`MR. HOUGH: Hold on. Objection to
`
`form.
`
`Please pause just a short amount of
`
`time to let me --
`
`THE WITNESS: Sure.
`
`MR. HOUGH:
`
`-- to make an objection if
`
`I want to.
`
`THE WITNESS: Okay.
`
`A.
`
`Yes. This was to demonstrate that we
`
`could mark diamonds, yeah. Could inscribe them
`
`with the inscription
`
`with the features that
`
`are needed for gemstone inscription.
`
`Q.
`
`And why was Potomac Photonics
`
`interested in inscribing the diamond gemstones
`
`for Lazare Kaplan?
`
`A.
`
`Well, we were in the laser
`
`22 micromachining equipment business, and we saw
`
`23
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`24
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`25
`
`that as an equipment business opportunity to do
`
`that. And that was the way that was presented in
`
`our initial discussions with Lazare Kaplan.
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`They had some equipment already in
`
`place and wanted us to think about servicing it
`
`or helping them upgrade it, replace it with some
`
`5 more modernized equipment. So that was really
`
`6
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`7
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`8
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`what was driving most of this work.
`
`It happened that we were also -- Well,
`
`I think even before we met them we were also
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`9 working on laser cutting and drilling of
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`diamonds. So this fit in well with some ongoing
`
`work that we were doing.
`
`Q.
`
`And so was the goal of the Potomac
`
`Photonics's efforts with respect to marking the
`
`gemstones for Lazare Kaplan to sell equipment to
`
`Lazare Kaplan?
`
`A.
`
`Q.
`
`It was, uh-huh.
`
`When the Potomac Photonics lab table
`
`machine was used to inscribe diamond gemstones
`
`for Lazare Kaplan did it use a pulse laser energy
`
`source?
`
`A.
`
`Q.
`
`A.
`
`It did.
`
`Can you describe that for me?
`
`Well, we -- we actually began our work
`
`24 with
`
`on laser machining like described in this
`
`25
`
`Exhibit 216 with a UV laser, a pulsed UV laser,
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`C.P. CHRISTENSEN
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`and then we
`
`partially as a result with the
`
`interaction was Lazare Kaplan decided to not -(cid:173)
`
`in proposed equipment to them, to not propose a
`
`UV laser system in view of the environment it
`
`would be working in. We thought it wouldn't be
`
`as reliable as we would like it to be.
`
`So we procured the loan of a frequency
`
`doubled green YAG laser, pulsed YAG laser that
`
`was suitable for this kind of thing. But both of
`
`these were pulsed, and we started out with UV,
`
`but we thought for this particular application it
`
`would make more sense to go to a green system.
`
`Q.
`
`Was the laser that was used to
`
`inscribe the diamond gemstones for Lazare Kaplan
`
`focused by an optical system onto the diamonds
`
`that you inscribed for them?
`
`A.
`
`Q.
`
`Yes, it was. Uh-huh.
`
`Okay. Were the diamond gemstones that
`
`you inscribed for Lazare Kaplan mounted in a
`
`mounting system?
`
`A.
`
`Yeah.
`
`In various ways it was
`
`necessary to fixture the diamonds so they could
`
`be moved under the focused beam and also rotated
`
`when it got to marking gemstones. When we were
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`TSG Reporting - Worldwide
`
`877-702-9580
`
`IPR2015-00024
`
`Lazare Kaplan International, Inc. Exhibit 2011 Page 25
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`C.P. CHRISTENSEN
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`doing the flat end caps we just needed to do a
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`planer sort of motion, XY motion.
`
`But in all of our setups we had as
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`needed the ability to do a rotation as well. And
`
`there was even a small grasping fixture that
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`Lazare Kaplan gave us that turned out to be quite
`
`handy in holding the gemstones themselves. For
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`the flat end cap work, we really just kind of set
`
`it on a table and attached it with an adhesive or
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`something to a table that could be moved under
`
`the focus beam.
`
`Q.
`
`And was the mounting system that you
`
`used on the Potomac Photonics lab table machine
`
`available for the LMT-1000?
`
`A.
`
`The LMT-1000 had the capability of
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`having, as.I recall -- I'm a little fuzzy on
`
`these various synchronizations of the LMT. But,
`
`for example, I pointed -- in fact, I'm a little
`
`fuzzy about whether the LMT-1000 had this shape
`
`that we talked about.
`
`I know that the 2000 and
`
`the 4000 had that.
`
`We started out with a very crude -- in
`
`our very first systems, a very crude setup that
`
`just focused the beam onto a work surface, and
`
`TSG Reporting - Worldwide
`
`877-702-9580
`
`IPR2015-00024
`
`Lazare Kaplan International, Inc. Exhibit 2011 Page 26
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`Page 27
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`C.P. CHRISTENSEN
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`the operator could move it with some sort of
`
`either computer or joystick control.
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`And I think in our very first trade
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`show exhibit we had a microscope just looking in
`
`from the side. But that quickly went to a
`
`viewing through the objective.
`
`So I'm wondering what we called that
`
`very first system that we exhibited at the trade
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`show. That might have been the 1000 or it might
`
`not have.
`
`I just don't recall.
`
`Q.
`
`A.
`
`uh-huh.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`So did the LMT-2000 have the --
`
`The 2000 would have, yes. Definitely,
`
`Let me finish my question.
`
`I'm sorry.
`
`You're anticipating it.
`
`Sorry.
`
`Did the LMT-2000 have the mounting
`
`system that. you used for inscribing the
`
`gemstones?
`
`A.
`
`It didn't have the -- there was a
`
`little grasping structure that would -- it was
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`like a post with some wires that came out and
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`hooked around the gemstone, and then you can
`
`TSG Reporting - Worldwide.
`
`877-702-9580
`
`IPR2015-00024
`
`Lazare Kaplan International, Inc. Exhibit 2011 Page 27
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`Page 28 •
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`.
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`I·
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`ii
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`I•
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`::
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`C.P. CHRISTENSEN
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`mount that post in a rotation stage. Now, we had
`
`the rotation stage but we didn't necessarily
`
`furnish that post to hold the gemstone.
`
`Q.
`
`Would that post to hold the gemstone
`
`fit on the LMT-2000?
`
`A.
`
`Q.
`
`Sure, it would, uh-huh.
`
`And was the mounting system used to
`
`hold the gemstone available for the LMT-4000?
`
`A.
`
`It would have been.
`
`I had the
`
`impression it was a commercial device.
`
`It wasn't
`
`specially fabricated. But I don't know where it
`
`was available.
`
`It was just -- we were just
`
`provided with that.
`
`Q.
`
`But you in fact used that on the
`
`Potomac Photonics lab table machine?
`
`A.
`
`Q.
`
`We did, yes, for marking gemstones.
`
`To make inscriptions on the diamond
`
`gemstones for Lazare Kaplan, was the focus laser
`
`energy directed onto a desired portion of the
`
`gemstone?
`
`A.
`
`Q.
`
`It was, uh-huh.
`
`On the Potomac Photonics lab table
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`24 machine?
`
`25
`
`A.
`
`It was.
`
`TSG Reporting - Worldwide
`
`877-702-9580
`
`IPR2015-00024
`
`Lazare Kaplan International, Inc. Exhibit 2011 Page 28
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`Page 29
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`C.P. CHRISTENSEN
`
`Q.
`
`A.
`
`Can you describe how that was done?
`
`It was done in a way that's very
`
`similar to these diagrams that we've been looking
`
`at. Typically the laser would go through some
`
`optics which would expand the beam or shape the
`
`beam.
`
`In the case of the green laser, expand the
`
`beam to a proper size and then it would be
`
`directed downward through a focusing objective
`
`and focused onto the work surface.
`
`Q.
`
`When you inscribed the diamond
`
`gemstones for Lazare Kaplan, was an image
`
`generated of the gemstone?
`
`A.
`
`It was --
`
`MR. HOUGH:
`
`I'm sorry. Objection to
`
`form.
`
`Go ahead.
`
`A.
`
`We typically would use for -- for --
`
`I'll just make it a simple answer. Yes, there
`
`was a video camera that would b
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