TODD SQUIRES, Ph.D.
`June 2, 2016
`
`1 (Pages 1 to 4)
`3
`
` I N D E X O F E X A M I N A T I O N
`Examination by: PAGE
` MS. ELLISON 4
`
` INDEX OF EXHIBITS
`
`EXHIBIT DESCRIPTION PAGE
`
` 1029 Hand-drawn diagram; 76
`
`4
`
` Redwood Shores, California, June 2, 2016
` 9:01 a.m.
`______________________________________________________
` MS. ELLISON: Good morning, Everyone. We'll
`take a roll call just to identify who's here. I'm
`Eldora Ellison on behalf of 10x Genomics. I'm from
`Sterne Kessler Goldstein & Fox; and I'm here together
`with my partner Deborah Sterling.
` MR. WALTER: Derek Walter of Weil, Gotshal &
`Manges for RainDance.
` THE WITNESS: Todd Squires from UCSB with
`RainDance.
` MS. ELLISON: Thank you.
` TODD SQUIRES,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MS. ELLISON:
` Q Dr. Squires, you understand that you are now
`under oath; right?
` A Yes.
` Q And is it your understanding that you're here
`to answer questions that I ask of you today?
` A Yes.
` Q Have you been deposed before?
` A Yes.
`
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`1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ------------------------------
` 10X GENOMICS, INC.
` Petitioner
` v
` RAINDANCE TECHNOLOGIES, INC.
` Patent Owner
` __________________________
` Case IPR2015-01558
` Patent 8,658,430
`
` ------------------------------
`
` DEPOSITION OF TODD SQUIRES, Ph.D.
`
`DATE: Thursday, June 2, 2016
`TIME: 9:01 a.m.
`LOCATION: WEIL GOTSHAL & MANGES LLP
` 201 Redwood Shores Parkway
` Redwood City, California
`
`REPORTED BY: LYNNE M. LEDANOIS, C.S.R. 6811
`JOB NO. 112287
`
`2
`
` A P P E A R A N C E S:
`
`For Patent Owner RainDance Technologies:
`WEIL GOTSHAL & MANGES LLP
`BY: DEREK C. WALTER, ESQ.
`201 Redwood Shores Parkway
`Redwood Shores, California 94065-1134
`650.802.3934
`derek.walter@weil.com
`
`For the Petitioner:
`STERNE KESSLER GOLDSTEIN & FOX
`BY: ELDORA LYNN ELLISON, Ph.D.
`1100 New York Avenue NW
`Washington, D.C. 20005
`203.371.2600
`eellison@skgf.com
`
`Also Present: Deborah Sterling, Ph.D., Sterne Kessler
`
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
`5
`
` Q How many times?
` A One.
` Q And what case?
` A This was a year ago approximately, last
`September. It was an IPR with -- Fluidigm was the party
`that I represented -- or I'm not sure of the right way
`to say it.
` Q You had provided test --
` A On whose -- on whose behalf I provided expert
`testimony.
` Q Okay. Which law firm handled that case?
` A Novak Druce and a few other names.
` Q You worked with Novak Druce?
` A That's correct.
` Q Okay. I'm just going to go over a few of the
`ground rules. You might remember some of these from
`when you were previously deposed.
` So I'm going to ask you questions today, and
`I'll ask that you provide answers out loud; okay?
` A Uh-huh. Okay. As opposed to "uh-huh"?
` Q Yeah. "Uh-huh" is out loud; but since the
`court reporter is transcribing what each of us say, it's
`best that we answer with full words.
` A Okay.
` Q Okay. At any time you need to take a break,
`
`6
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`just ask and I'll try to accommodate you; but I'll ask
`that if there is a question pending, that you wait until
`after you answer the question before taking a break;
`okay?
` A Okay.
` Q And counsel for RainDance may object to some of
`my questions; but unless they instruct you not to answer
`the question, you still need to answer the question.
`Okay?
` A Okay.
` Q As you can see, the court reporter is
`transcribing what we're saying. So I'll try not to talk
`over you, and I'll ask that you try not to talk over me.
`Fair enough?
` A Yes.
` Q And if you need clarifications for any
`question -- for example, if you don't understand my
`question -- just ask me for clarification.
` You cannot ask counsel for RainDance for
`clarification. You have to ask me, and we'll try to
`clarify the question for you; okay?
` A Yes.
` Q Also, when we're on breaks today, the rules of
`the Patent Office do not permit you to discuss the
`substance of your testimony with counsel for RainDance.
`
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`2 (Pages 5 to 8)
`7
`
` Do you understand that?
` A Yes.
` Q And you agree to abide by that?
` A Yes.
` Q Thank you.
` So I'm going to start with the very standard
`question you probably heard before, which is what did
`you do to prepare for today's deposition?
` A I met yesterday with counsel, and we reviewed
`documents to refresh my memory about the facts of the
`case.
` Q With whom did you meet?
` A With Derek Walter.
` Q Anyone else?
` A No.
` Q Did you review any documents that were not
`cited in your declaration?
` A No.
` Q Did you review all the documents that are cited
`in your declaration?
` A Not together with Derek, no.
` Q I see you have a stack of documents in front of
`you. Can you tell me what you have in front of you?
` A These are copies of the documents that are
`cited in my declaration. So would you like for me to
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`read what they are or --
` Q Is -- is it only cop --
` A Go ahead.
` Q Is it only copies of what's cited in your
`declaration?
` A Well, there is -- my declaration is here.
`I'll -- why don't I just read them. There is the '430
`patent. There is the petition for the IPR; Huck's
`declaration; preliminary response; the Institute
`decision; patent owner's response; my declaration;
`Link's declaration; the Link patent; and Nguyen.
` (Discussion off the record.)
`BY MS. ELLISON:
` Q Are there any markings on the documents in
`front of you?
` A No, there are not.
` Q When were you retained to work on this IPR?
` A Early last year.
` Q So that's early 2015?
` A Early 2015.
` Q Do you recall what month?
` A I don't. Sorry.
` Q So when you say "early," is that like first
`quarter?
` A I would think so. I was first contacted and
`
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
`9
`then there was a stretch of time where I heard nothing,
`but I don't remember exactly.
` Q Okay. How much time have you spent working on
`this case?
` A In preparing the declaration?
` Q Total.
` A Total, probably 40 to 50 hours.
` Q Okay. And of those 40 to 50 hours, how much
`time did you spend preparing the declaration?
` A It was 30 --
` Q Approximately.
` A -- 30 to 40, something like that.
` Q Okay. And how much time did you spend
`preparing for today's deposition?
` A Basically yesterday and part of the day before.
`So 10, 15 hours, something like this.
` Q Okay. Even though it seems that you have a
`copy of your declaration in front of you, I'm going to
`hand you a copy of it anyway. You're welcome to work
`with whatever version you wish. So I'm handing you a
`copy of RainDance Exhibit 2012.
` Do you recognize that as the declaration you
`submitted in this IPR?
` A Yes.
` Q And that's your signature that appears just
`
`10
`
`before Appendix A on Page 79; is that correct?
` A Yes.
` Q Is there anything in your declaration that you
`wish to correct?
` A I noticed a couple of typos in the formulas.
`I'm not sure if you worked through the formulas, but I
`could clarify those if you would like. But that's
`basically it. That's the only thing that -- I have to
`find them.
` So in Paragraph 55, the second line says have
`the same -- so the two sample channels have the same
`resistance, RWO. That should just be RW.
` Q I'm sorry. One second so I can catch up with
`you.
` You said in Paragraph 55?
` A 55.
` Q It appears on Page 23?
` A On Page 23, correct.
` Q The second line says [as read]: R -- have the
`same resistance, RWO.
` And it should be what?
` A RW.
` [As read]: The carrier fluid channels have the
`same (inaudible) --
` THE REPORTER: The what?
`
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`3 (Pages 9 to 12)
`11
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` THE WITNESS: Oh, I'm sorry. This is in -- now
`it's Line 3. [As read]: The two carrier fluid channels
`(2 and 3) have the same resistance RO.
` It should be RC. Stands for carrier.
` And then the last correction there is [as
`read]: The two outlet channels (5 and 6) have the same
`resistance RO.
` Q Okay.
` A Okay. The channel DF has resistance RM, rather
`than MO.
` And then if you're ready, there is a misplaced
`parentheses in the equation following immediately before
`58, Paragraph 58. So it's on Page 24. The
`parentheses -- how do I describe this? The closing
`parentheses, which is second from the end of the
`equation, that should be struck; and it should -- that
`should instead appear at the very end of the equation
`because that -- this -- there is a -- the typo there,
`which should be consistent with my Appendix A, which
`is -- so it would be Equation 42 of my Appendix A, and
`that's on Page A-3. So that is where it reads
`correctly.
` Q Anything else?
` A Very, very minor. The last two things in
`Appendix A, and it's just messed-up notation a little
`
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`bit.
` Equation 6 and 7 it says "Q2 equals" in both of
`those.
` It should be -- the first one is Q2 -- I'll
`wait till you're there.
` Q Go ahead.
` A All right. So the first one is Q2 equals --
`the first -- so Equation 6 is correct. Equation 7
`should be Q3 equals.
` You can kind of see the order there, the logic
`of that.
` Q Anything else?
` A And then the same -- the same appears on
`Equation 18. I have Q2 twice in a row. So Equation 17
`is correct. Equation 18 should be Q3.
` Q Anything else?
` A That is it.
` Q So how did these errors come to your attention?
` A When I was reviewing my declaration, checking,
`just making sure that things were consistent, I just
`noticed that there was a typo.
` Q So with the corrections that you just made, do
`you stand by the testimony set forth in your
`declaration?
` A Yes. All -- none of the conclusions are
`
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
`13
`changed if one were to try to work through the math.
`It's -- it's pretty obvious to me, you know, the -- the
`errors that were there were just typos basically; but I
`wanted to be sure to be complete.
` Q Appendix B of your declaration provides a list
`of materials considered; correct?
` A Correct, yes.
` Q Is this the complete list of materials you
`considered in formulating the opinions set forth in your
`declaration?
` A No. It's not complete.
` Q What's missing?
` A This -- so this list is a list of materials
`that are weighed upon heavily in this and are cited in
`this in the declaration.
` I've been a professor for 11 years, and I've
`been in this field for 20 something. So, I mean, my
`acknowledge I considered -- I mean, many, many things
`just -- you know, it's hard to disentangle what I just
`happen to know from, you know...
` Q I'm entitled to know specifically which
`documents you relied on in formulating your opinions.
`So --
` A These are the documents that I relied upon to
`formulate my opinion.
`
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` Q When you say "these" --
` A These, the ones that are in Appendix B.
` Q Okay. Are there any other specific documents
`you relied on in formulating your opinions other than
`those listed in Appendix B?
` A Not that I am aware of, not that I can recall.
`I can look at -- no, this is the -- this is the list.
` Q In carrying out your work in connection with
`this IPR, have you conducted any searching of the
`literature?
` A Yes.
` Q And have you conducted any searching of patents
`or patent applications?
` A Let me think about that. I do not remember
`specifically searching for patents or patent
`applicate -- patent applications.
` Q In searching literature, what did you search
`for?
` A I searched for scholarly articles or articles
`from the published literature or just more generally
`scientific information.
` Q How did you carry out that searching?
` A Well, I would have used databases that are
`online, so Web of Science is one that I use quite a bit.
` THE REPORTER: Web of Science?
`
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`4 (Pages 13 to 16)
`15
` THE WITNESS: Web of Science, yeah. ISI Web of
`Knowledge, Web of Science, something like this. It's
`changed names since I have been a professional.
` Google Scholar, Google.
`BY MS. ELLISON:
` Q So you searched Web of Science?
` A Probably. I mean, I -- I assume I did. It's
`the kind of thing that I do with some frequency, so...
` Q But you're not -- you're not sure?
` A I don't remember specific instances, but I
`imagine that I did.
` Q Okay. Did you carry out Google searching or
`are you not sure?
` A I imagine that I did. I mean, it's a pretty
`routine thing to do, so probably.
` Q But you're not sure?
` A I can remember -- I'm trying -- so I'm trying
`to remember specific times where I specifically did a
`Google search. One I did in order to basically look up
`what the pressure regulators are that we use in our lab.
`You know, look up the company.
` Q So you looked up the name of the company that
`provides the pressure regulators used in your labs; is
`that correct?
` A Yeah, that's correct. I mean, I'm just trying
`
`16
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`to think of examples where -- you know, specific
`examples where I was -- I mean, I assume I -- I could
`have gone to my lab and just looked; but I was in my
`office and, you know, I knew it started with Elva and I
`couldn't remember the rest of it. So I -- you know, I
`mean, that's one example where I did it.
` I'm sure that there are others. I don't
`remember specific ones. I don't remember what I
`searched for, but just trying to think about it.
` Q Okay. Can you recall any other databases that
`you searched?
` A I cannot recall other databases, no.
` Q Other than looking at the name of the company
`that provides the pressure regulators that you used in
`your lab, can you think of anything else that you
`searched for in carrying out your work on this IPR?
` A I would have done generic searches for the
`droplet literature, but it's a big literature. So
`specifically, I mean -- and that I would have done with
`Web of Science.
` Q You say you would have done it?
` A Yeah. I -- I -- that's -- if I were -- I mean,
`I don't remember the specific times that I did it; but
`if -- if I were to run a simulation of Todd Squires in
`his office saying, okay, how would I look for
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
`17
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`literature, that's what would I do.
` Q Do you have a specific recollection of having
`searched the literature?
` A I don't have a specific recollection of the
`times or the -- the instances where I did, no; but I
`imagine that I did.
` Q But you're not sure that you searched the
`literature; correct?
` It's okay if you're not sure. I'm just --
` A Yeah.
` Q -- trying to understand your testimony.
` A It's hard for me to imagine that I didn't, but
`I cannot point to specific -- specific instances where I
`did, that I documented. And I -- I mean, I -- and so in
`that regard, with me sitting here under oath and trying
`to provide as accurate of testimony as I can, you know,
`I mean, I -- maybe that's the best that I can do.
` Q Do you recall any specific search terms that
`you used to search the literature?
` A No, I don't, I mean, other than this Elva
`something for the pressure regulator. I mean, I
`remember doing that one specifically just because I
`remember wanting to know what the company was that we
`bought it from and, you know, not leaving my office to
`do it.
`
`18
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` Q Understood.
` Do you recall looking for literature as of any
`particular time period?
` A No, you know, insofar as I don't -- I don't
`recall specifically looking for literature. I mean,
`I -- I -- I'm sure that I did, right, and so limiting
`where it is that I looked would be hard for me to do.
`You know, so...
` Q Okay. In carrying out your work in connection
`with this IPR, did you seek to obtain copies of any
`particular documents other than those listed in
`Appendix B of your declaration?
` A Did I -- could you repeat the question.
` MS. ELLISON: Could you read it back, please.
` (Requested testimony read back.)
` THE WITNESS: There are some documents here --
`I guess that's not in preparation for the IPR. I'm just
`trying to be careful here.
` By "seek to obtain," do you mean did I ask
`counsel for or --
`BY MS. ELLISON:
` Q That's one way of seeking to obtain
`information --
` A Okay.
` Q -- or seeking to obtain documents?
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`5 (Pages 17 to 20)
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` A I don't -- I don't recall seeking to obtain
`documents in that fashion. If by "seeking to obtain,"
`you mean do a Google search or a Web of Science search,
`then I've talked about that; and I probably did. But I
`don't remember exactly what -- beyond that, I can't
`recall specific cases where I sought to obtain documents
`in this regard.
` Q Okay. You understand that this IPR involves
`U.S. Patent Number 8,658,430?
` A Yes.
` Q I'll refer to that as the '430 patent; okay?
` A Uh-huh, yes.
` Q Have you read the '430 patent?
` A Yes.
` Q Did you understand it?
` A I believe so, yes.
` Q Is there anything in the '430 patent that you
`did not understand?
` A I do not believe so.
` Q I'll give you a copy of the '430 patent, which
`is --
` A Okay.
` Q -- Exhibit 1001.
` A This is actually a different patent.
` MS. STERLING: Yes, it is.
`
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`BY MS. ELLISON:
` Q Well, you have a copy of the '430 patent in
`front of you; right?
` A Yes.
` MS. STERLING: Sorry.
`BY MS. ELLISON:
` Q Sorry about that. We have a few technical
`glitches.
` A That's all right.
` So '430. Here it is.
` Q Do you have an understanding of what's claimed
`in the '430 patent?
` A Yes.
` Q Do you have any patents yourself?
` A I have one. I have one that's listed in my
`C.V.
` Q Do you have any pending patent applications?
` A I do not believe so, no.
` Q In preparing your declaration, did you seek to
`understand what is claimed in the '430 patent?
` A Yes.
` Q So you understand the scope of the '430 patent
`claims?
` A I believe so, yes.
` Q And do you know what a dependent claim is?
`
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
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` A Yes, I believe so.
` Q What's your understand -- what's your
`understanding of what a dependent claim?
` A My understanding of a dependent claim -- and I
`am not a lawyer, as you know -- is: It is a claim that
`it depends upon a prior claim.
` Q Do you understand that dependent claims are
`more narrow in scope than independent claims from which
`they depend?
` A My -- yes. My understanding of dependent
`claims are those are claims that take an independent or
`maybe a chain of claims before them, but they -- they
`add something which makes a more specific aspect of an
`invention or a more specific claim.
` So it -- in -- in that regard, it narrows the
`scope because it provides additional details that are
`not in the independent claim. That's my -- it's not a
`very concise way of describing it, but...
` Q So is it your understanding that an independent
`claim can include subject matter that's not included in
`the dependent claim?
` A My -- I do not -- so I don't think that I agree
`with that. My belief is that the dependent claims say,
`oh, the method of Claim 1 where, dot, dot, dot, dot,
`dot, dot.
`
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` And so the dependent claim contains the aspects
`of the independent claim and then they add additional
`aspects. I'm not sure if "limitations" is the right
`word for it, but that's my understanding.
` Q Limitations works.
` A Okay.
` Q So is it your view that a dependent claim is of
`the same scope as an independent claim?
` A My understanding is that a dependent claim
`includes what is claimed in the independent claim on
`which the dependent claim depends. And it adds an
`additional detail which limits or changes or provides
`extra specificity to that particular claim.
` Q I think earlier you said a dependent claim
`further narrows an independent claim.
` Is that your understanding?
` A So I have to be careful here because you're
`trained in law. My Counsel is trained in law. I am
`not.
` These are -- these are terms that carry very
`specific legal meanings, I know, in patent law; and it
`is not my area of expertise. I'm uncomfortable trying
`to provide definitions of what these terms mean because
`I know that they mean something.
` What I'm trying to do is to give you my
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`6 (Pages 21 to 24)
`23
`understanding of what these terms mean, how I interpret
`them.
` So if "narrow the scope" means something very
`specific in a patent law sense, then my words are not
`meant to connote something very specific.
` What I'm trying to say is that the dependent
`claim -- the way that I have thought about it would be
`the dependent claim is like saying that you have the
`independent claim -- it's -- it's almost like a
`shorthand where you could just copy the independent
`claim and just insert it into the beginning of the
`dependent claim. That is how I -- how I have viewed it.
` Whether you say that that narrows the scope or
`expands the scope, I'm not comfortable really -- I -- I
`would have to really think about how to say that well.
` My understanding is basically that the
`dependent claims are ones that -- that take what has
`come before them upon which they depend, and it adds
`some additional information.
` Q Okay. Just to be clear, I'm not asking for a
`legal opinion.
` A Okay.
` Q I know you're not a lawyer.
` A Uh-huh.
` Q I'm asking for -- I'm trying to understand your
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`understanding of how the claims relate to each other.
` A Okay.
` Q And given that you've opined with respect to
`the claims, I think I'm entitled to understand that.
` A Yes.
` Q Okay. So I'm not trying to force any words
`upon you, so you can use your own words, but I'm
`entitled to understand what your understanding is of how
`these claims relate to each other.
` A I understand that.
` Q Okay. So let's take an example. Let's look at
`the claims of the '430 patent, Claims 1 and 2, for
`instance. Instead of 1 and 2, let's look at Claims 1
`and 3, for instance.
` Do you see that Claim 3 depends from Claim 1?
` A Yes, because Claim 3 says "the method of Claim
`1 wherein" and then it provides additional information.
` Q Right.
` A Yes.
` Q Is it your understanding that Claim 1 includes
`subject matter that is not included within Claim 3?
` MR. WALTER: Objection, form.
` MS. ELLISON: I'll ask it differently.
` THE WITNESS: Yeah.
`BY MS. ELLISON:
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
`25
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` Q Is it -- do you understand that Claim 1
`encompasses subject matter that is not encompassed by
`Claim 3?
` A The question is: Do I understand that Claim 1
`encompasses subject matter that is not encompassed by
`Claim 3?
` Q Correct.
` A Can I ask for clarification?
` Q Sure.
` A Are you asking whether I can read Claim 3
`without -- without reading Claim 1?
` Q No.
` A Or are you saying there is information or
`subject matter in Claim 1 that does not apply when
`Claim 3 is read? Do you understand what I'm asking?
` Q I'm not sure what you mean by that.
` A Okay. So when -- so you're asking do I
`understand that Claim 1 contains subject matter that is
`not in Claim 3.
` Q Correct.
` I'll ask it a little differently.
` A Yeah, please.
` Q Okay. Have you heard people say the claim
`"covers certain embodiments"? Are you familiar with
`that kind of terminology --
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` A Yes.
` Q -- "covers"?
` A Yes.
` Q Are you comfortable with that terminology?
` A In a vague, you know, nonlegal sense, yes.
` Q Well, let me --
` A Yeah, but I -- but I -- yes, I think so.
` Q What is your understanding when someone says
`the claim "covers" certain things?
` A Certain embodiments?
` Q Right.
` What does that mean to you?
` A I'm trying to be careful in how I respond.
` So what that means is that the -- a particular
`realization of the invention or a particular example of
`the invention is described by the claim. So the
`elements of this claim describe the key aspects or the
`important -- the essential aspects of a -- of an
`invention.
` It's harder for me, I will say, to speak in the
`abstract than it is to speak in more concrete terms, but
`I'm trying. I'm sorry. So my -- my difficulty -- if I
`can return to your previous question --
` Q Please.
` A Because I'm -- I'm just -- I'm trying to avoid
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`7 (Pages 25 to 28)
`27
`saying something that you're not asking and that I don't
`mean.
` So clearly, the information in Claim 1 is
`different than the information in Claim 3; right. My
`understanding, however, is that in order to properly
`read Claim 3, say the dependent claim, that also
`incorporates all of the information in Claim 1.
` What was unclear to me in your question was
`whether you are asking whether there is some information
`in Claim 1 that does not apply when you read Claim 3.
` Q I'll ask it this way.
` A Okay.
` Q Does Claim 1 cover embodiments that are not
`covered by Claim 3?
` A Yes.
` Q Okay.
` A Much better. Thank you.
` Q Thank you.
` And so generally does an independent claim
`cover embodiments that are not covered by a claim that
`depends from the independent claim?
` A Yes, my understanding is that an independent
`claim can cover embodiments that are not covered by
`dependent claims because there can be multiple dependent
`claims that describe different aspects,
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`different whatever -- yes.
` Q All right. Thank you.
` A Particularly, since some of these dependent
`claims do different things.
` Sorry that that took awhile to get there but...
` Q Well, I appreciate your cooperation in getting
`there. I just wanted to make sure I understood that.
` Dr. Squires, have you published any papers
`on -- relating to droplets in microfluidics?
` A The most relevant one -- so I should -- I
`should look.
` Do you have a copy of my C.V? This is -- this
`is actually not in this binder here.
` MS. STERLING: The box is full of surprises.
`There we go, yes.
` THE WITNESS: The ones that I can recall -- let
`me -- let me just be careful and read -- read this list
`and make sure that I am not --
`BY MS. ELLISON:
` Q Well, as you review your C.V., if you can
`identify for me any publications that you have on
`microfluidics -- excuse me -- on droplets in
`microfluidics, I would appreciate it.
` A Okay. I'm starting on -- on -- well, it's a
`reverse chronological list, but Publication Number 64.
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`TODD SQUIRES, Ph.D.
`June 2, 2016
`
`29
`That involves droplets in microfluidics. There are many
`of these papers that relate to the science. Most of
`what I do is -- is more scientific rather than
`application oriented. And so some of these papers would
`relate to the science that are related to droplets in
`microfluidics but aren't specifically directed towards
`droplets in microfluidic devices.
` So the -- I'm not sure whether you want to be
`as inclusive as I can be or very specific. Reference
`42, Electrokinetics over Liquid -- Liquid Interfaces is
`a theory paper, meaning that we do analytical and
`mathematical studies of -- but that one involves a
`droplet, not specifically in a microfluidic channel,
`but -- but it's on the -- the Link scales that are
`relevant for microfluidics. And, you know, that's
`something that we had in mind.
` Reference 25 is -- is -- so I'm just trying to
`be inclusive at this point about things where it could
`apply to droplets by Link. Reference 25, The Influence
`of Hydrodynamic Slip on the Electrophoretic Mobility of
`a Spherical Colloidal Particle.
` THE REPORTER: Electrophoretic what?
` THE WITNESS: Electrophoretic. So it's
`Reference 25 -- p-h-o-r-e-t-i-c -- mobility of a
`spherical colloidal particle.
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` That is one that -- where the physics there is
`relevant to the physics of droplets in these contexts
`and I believe that we would have commented on that.
` Reference 13 is a review article that I wrote
`with Steve Quake. Microfluidics: Fluid Physics on the
`Nanoliter Scale. This is 2005.
` I wrote a viewpoint article, VP1, under the
`viewpoint section entitled, "Droplets on Soft Surfaces.
`Learn the Hard Way."
` Q Sorry --
` A Yeah. So that's --
` Q Oh, I see. VP1.
` A Yeah, VP1.
` Q On an unnumbered page?
` A Yeah.
` And that was a commentary piece or a
`perspective piece on a different researcher's work.
`Those are ones -- I mean, there are plenty of references
`in here that are related to fluid mechanics that are
`relevant for droplet motion, physics of droplets, et
`cetera; but they don't specifically deal with or discuss
`liquid drops and so I have not listed those.
` Q When you say "I have not listed those" --
` A I haven't mentioned those to you just now.
` Q Other than the specific papers you identified,
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`8 (Pages 29 to 32)
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`are there any papers -- any other papers of yours that
`disclose experiments carried out on droplets in a
`microfluidic device?
` A Are there any other papers that I have
`published?
` Q Yes.
` A Or that my lab has published? So our
`facility --
` Q On which you are an author.
` A Of which I am an author. Okay.
` Of those, the -- the one paper that I can point
`to right now that has experient