Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`1
`
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` ______________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ______________________
` GENERAL ELECTRIC COMPANY,
` Petitioner,
` V.
` UNITED TECHNOLOGIES CORPORATION,
` Patent Owner
` ________________________
` Case No. IPR2016-00862
` Patent No. 8,689,568
`
`
` Videotaped Deposition of Expert Witness
` JOHN EATON, Ph.D.
` Redwood City, California
` Tuesday, December 20, 2016
`
`
`
`REPORTED BY: Diane S. Martin, CSR 6464, CCRR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2003.001
`
`GE v. UTC
`Trial IPR2016-00862
`
`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`2
`
` Videotaped Deposition of Expert Witness
` JOHN EATON, Ph.D., taken at the law offices of:
`
` WEIL, GOTSHAL & MANGES, LLP
` 201 Redwood Shores Parkway,
` Suite 400
` Redwood City, California 94065
`
`
`
`
`
`
` Pursuant to notice, before Diane S. Martin,
`Certified Shorthand Reporter in and for the State
`of California.
`
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`UTC-2003.002
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`3
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` A P P E A R A N C E S:
`For the Petitioner:
` WEIL, GOTSHAL & MANGES, LLP
` BY: CHRISTOPHER M. PEPE, ATTORNEY AT LAW
` 1300 Eye Street, Suite 900
` Washington, D.C. 20005-3314
` 202-682-7000
` christopher.pepe@weil.com
`
`For the Patent Owner:
` FINNEGAN, HENDERSON, FARABOW, GARRETT &
` DUNNER, LLP
` BY: JASON STACH, ATTORNEY AT LAW
` 271 17th Street, N.W., Suite 1700
` Atlanta, Georgia 3-363-6209
` 404-653-6400
` jason.stach@finnegan.com
`
` PRATT & WHITNEY
` BY: JANICE V. JABIDO, ATTORNEY AT LAW
` 400 Main Street, M/S 132-13
` East Hartford, Connecticut 06118
` 860-565-2201
` Janice.jabido@pw.utc.com
`The Videographer: Jason Sayler
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2003.003
`
`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`4
`
` INDEX OF EXAMINATION
`EXAMINATION BY: PAGE
`MR. STACH 6
`MR. PEPE 108
`
`
` INDEX OF EXHIBITS
`EXHIBIT PAGE
`EXHIBIT UTC 2001 US Patent Application US 45
` 2011/0293423
`
`
` --oOo--
`
`
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`UTC-2003.004
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`5
`TUESDAY, DECEMBER 20, 2015 9:02 A.M.
`09:01:13
` P R O C E E D I N G S
`09:01:13
` --oOo--
`09:01:13
` THE VIDEOGRAPHER: Good morning. We're on
`09:01:13
`the video record at 9:02 a.m. I am Jason Sayler
`09:02:05
`from Henderson Legal Services in Washington, D.C.
`09:02:12
`The phone number is 202-220-4158.
`09:02:17
` This is a matter pending before the U.S.
`09:02:24
`Patent and Trademark Office, before the Patent
`09:02:29
`Trial and Appeal Board, in the case captioned
`09:02:33
`General Electric Company versus United Technologies
`09:02:38
`Corporation, case number IPR 2016-00524.
`09:02:42
` This is the beginning of Tape Number 1 of
`09:02:52
`the deposition of John Eaton on December the 20th,
`09:02:55
`2016. We're located at 201 Redwood Shores Parkway,
`09:03:00
`Suite 50,0 in Redwood Shores, California. This is
`09:03:09
`taken on behalf of the patent owner.
`09:03:15
` Counsel and all present, would you please
`09:03:18
`identify yourself, starting with the questioning
`09:03:20
`attorney.
`09:03:23
` MR. STACH: Thank you.
`09:03:24
` One -- one quick correction. Our case
`09:03:27
`number is different than the one you read out.
`09:03:30
`Could I provide that to you?
`09:03:32
` THE VIDEOGRAPHER: Yes, please.
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`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`6
` MR. STACH: And by the way, this is Jason
`09:03:34
`Stach speaking on behalf of patent owner, United
`09:03:36
`Technologies Corporation. And with me today is
`09:03:39
`Janice Jabido of Pratt & Whitney.
`09:03:42
` The case number is IPR 2016-00862.
`09:03:45
` THE VIDEOGRAPHER: Thank you.
`09:03:54
` MR. PEPE: My name is Chris Pepe from Weil,
`09:03:56
`Gotshal & Manges, and I'm here on behalf of the
`09:03:58
`petitioner, General Electric.
`09:04:02
` THE VIDEOGRAPHER: Would the court reporter
`09:04:05
`please swear in the witness.
`09:04:06
` JOHN EATON, Ph.D.,
`09:04:16
`called as a witness, after having been duly sworn
`09:04:16
`by the Certified Shorthand Reporter to tell the
`09:04:16
`truth, the whole truth, and nothing but the truth,
`09:04:16
`testified as follows:
`09:04:16
` THE VIDEOGRAPHER: Please proceed.
`09:04:16
` EXAMINATION
`09:04:17
`BY MR. STACH:
`09:04:17
` Q. Dr. Eaton, thank you for joining us this
`09:04:17
`morning.
`09:04:21
` You understand you're under oath now today?
`09:04:22
` A. Yes.
`09:04:24
` Q. And have you been deposed before?
`09:04:25
` A. No. Not -- not for a long time, if I have.
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`UTC-2003.006
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`7
`I've been in a arbitration hearing for a personal
`09:04:33
`lawsuit against -- or actually a personal
`09:04:37
`arbitration against a contractor. But never in a
`09:04:39
`patent-type situation.
`09:04:42
` Q. And you've never, then, been deposed as an
`09:04:44
`expert witness before --
`09:04:48
` A. No.
`09:04:51
` Q. -- is that correct?
`09:04:51
` Have you ever offered expert witness
`09:04:51
`opinions in any other prior case before?
`09:04:53
` A. Never that -- one that completed. So I was
`09:04:56
`asked, more than 30 years ago, to perform an
`09:05:00
`experiment on -- to show that two devices were
`09:05:05
`really the same, and -- and then the case settled
`09:05:07
`before I was done with it.
`09:05:10
` Q. You said that was 30 years ago or so?
`09:05:11
` A. At least, yeah. I was a new assistant
`09:05:14
`professor.
`09:05:17
` Q. Okay. Well, I'll go over a few preliminary
`09:05:17
`guidelines or rules, if you will --
`09:05:21
` A. Okay.
`09:05:23
` Q. -- about the deposition.
`09:05:23
` One thing that we need to try to do is not
`09:05:25
`talk over one another. So I'd appreciate if -- if
`09:05:27
`I'm asking a question, if you'll wait until the
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`8
`question is complete to answer. That's more to
`09:05:32
`make sure we get a clean record with the court
`09:05:34
`reporter. She may stop us at certain points if she
`09:05:37
`needs clarification on spellings or -- or what was
`09:05:40
`said, or if we are just speaking too quickly.
`09:05:44
` So I just want to make sure we speak in
`09:05:47
`measured tones and -- and not talk over each other.
`09:05:50
` Do you understand that?
`09:05:52
` A. Yes.
`09:05:53
` Q. I'll be asking you questions today. Your
`09:05:54
`counsel may be objecting to some of those
`09:05:57
`questions. But unless he instructs you not to
`09:05:59
`answer on grounds of privilege, I ask that you
`09:06:03
`answer the question anyway.
`09:06:05
` Do you understand that?
`09:06:07
` A. Yes.
`09:06:07
` Q. And if I ask you a question that you don't
`09:06:07
`understand, please let me know, and I'll try to ask
`09:06:09
`a better question. I want to make sure the record
`09:06:13
`is clear here, and so, you know, if -- if you don't
`09:06:15
`understand the question, help me by -- by letting
`09:06:19
`me know that. Otherwise I'll understand that you
`09:06:21
`did understand the question and that your answer is
`09:06:24
`responsive.
`09:06:26
` Do you --
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`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`9
` A. Okay.
`09:06:27
` Q. -- understand that?
`09:06:28
` A. Yeah.
`09:06:28
` Q. We'll be taking some breaks today. If you
`09:06:28
`need a break, just let me know. We'll likely be
`09:06:31
`able to take it then. The exception is, if we have
`09:06:35
`a question pending, I would ask that you answer the
`09:06:38
`question before we take the break.
`09:06:40
` And do you have any questions -- or do you
`09:06:44
`understand that as well?
`09:06:51
` A. Yes.
`09:06:51
` Q. How did you prepare for today's deposition?
`09:06:52
` A. Do you mean the -- the recent preparation?
`09:06:58
`Or from start?
`09:07:01
` Q. Well, let's start with your recent
`09:07:03
`preparation.
`09:07:05
` A. So I reviewed the Kohli patent, the three
`09:07:06
`either patents or patent applications from Liang,
`09:07:17
`Lee and -- I'm blocking. I'd say Ron Bunker.
`09:07:23
` And I reviewed the document that I
`09:07:31
`submitted to -- before as my deposition, I reviewed
`09:07:35
`your response to it, and I reviewed the -- the
`09:07:40
`patent office's -- I'm not sure what that board
`09:07:44
`is -- opinion about it.
`09:07:46
` Q. When you mentioned the Kohli patent, are
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`10
`you referring to the '568 patent?
`09:07:54
` A. Right. I don't remember the -- yes. The
`09:07:56
`one in question, yes.
`09:08:00
` Q. So today if we refer to the Kohli patent or
`09:08:04
`the '568 patent, you'll understand what we're --
`09:08:09
` A. Yes.
`09:08:15
` Q. -- talking about? It's Exhibit 1001 in the
`09:08:16
`preceding.
`09:08:19
` A. Right.
`09:08:19
` Q. How long did you spend preparing for
`09:08:20
`today's deposition?
`09:08:21
` A. I think it was about 15 hours, about that.
`09:08:22
` Q. Did you meet with anyone during your
`09:08:27
`preparation?
`09:08:29
` A. Just I met with Chris yesterday for two
`09:08:30
`hours, I guess.
`09:08:33
` Q. Were there any other meetings by -- in
`09:08:37
`person or by telephone with counsel?
`09:08:41
` A. For this last preparation, not -- the last
`09:08:43
`time we met or talked was maybe April last year --
`09:08:46
`or April this year, I'm sorry. And then there were
`09:08:53
`a number of iterations by e-mail of fine points on
`09:08:56
`editing of the thing. I don't remember when those
`09:09:04
`ended. Sometime perhaps as late as June. I'm not
`09:09:07
`sure. And then we only talked to schedule after
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`11
`that.
`09:09:16
` Q. So other than meeting for two hours
`09:09:17
`yesterday, the last contact in person that you had
`09:09:23
`with counsel was sometime around April; is that
`09:09:26
`correct?
`09:09:30
` A. Yeah, last spring.
`09:09:30
` Q. And that was to prepare your declaration
`09:09:31
`for this proceeding; is that right?
`09:09:34
` A. Yes. We had talked before that on -- after
`09:09:36
`I had studied out all the materials and I'd talked
`09:09:40
`to him about what I thought, my opinion, and
`09:09:43
`then -- then we met to prepare the declaration
`09:09:48
`after that.
`09:09:51
` Q. Was anyone else present when you --
`09:09:51
` A. Anish Desai.
`09:09:56
` Q. So Anish Desai was present when you met
`09:09:58
`with Chris Pepe; is that correct?
`09:10:03
` A. Yes. Part of it. Most of the time.
`09:10:04
`Not -- not the whole time. Most of the time.
`09:10:06
` Q. Was anyone else present?
`09:10:13
` A. No.
`09:10:13
` Q. In your correspondence regarding your
`09:10:14
`declaration that you mentioned occurring after your
`09:10:25
`meetings in April, who did you correspond with
`09:10:28
`about that declaration?
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`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`12
` A. Chris.
`09:10:32
` Q. Again, that's Chris Pepe --
`09:10:32
` A. Yes.
`09:10:40
` Q. -- sitting here today?
`09:10:40
` A. Yeah.
`09:10:42
` Q. Was there anyone else who you corresponded
`09:10:43
`with about your declaration?
`09:10:48
` A. Anish may have been copied on some of
`09:10:50
`those, but I don't think so. It was mostly
`09:10:52
`interactions between Chris and me on.
`09:10:55
` Q. Did you change any -- any of your opinions
`09:11:07
`over the course of developing your declaration?
`09:11:10
` A. I think -- well, yes, I guess. I was
`09:11:12
`evolved through as I read it and tried to
`09:11:29
`understand it over and over. These things are very
`09:11:31
`ambiguous. I've probably read the '568 patent at
`09:11:34
`least 50 times, and my understanding of it evolved
`09:11:39
`with that.
`09:11:42
` Q. How did it evolve?
`09:11:47
` A. I continued to try to understand how
`09:11:51
`these -- these drawings, which aren't accurate
`09:11:54
`engineering drawings, what they meant. And -- and
`09:11:58
`then there was also terms, they are more legal than
`09:12:02
`engineering, that I was trying to understand what
`09:12:08
`they -- they meant. And I think the -- Chris Pepe
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`13
`had obviously studied these and was able to cite,
`09:12:19
`well, here they say lobe is a channel-like thing,
`09:12:22
`for example. I said okay.
`09:12:26
` I think -- so I don't remember the details
`09:12:31
`about it. I -- I had an opinion from the outset,
`09:12:34
`that I wrote, that pretty much is -- is reflected
`09:12:37
`in the deposition. I -- there wasn't any complete
`09:12:41
`changes. So ...
`09:12:46
` Q. Did you encounter any ambiguities in the
`09:12:48
`Bunker reference?
`09:12:53
` A. Yes.
`09:12:54
` Q. And what ambiguities did you encounter
`09:12:55
`there?
`09:12:58
` A. I think all of the drawings in both patents
`09:12:58
`are completely ambiguous. They do not specify a
`09:13:04
`shape at all. They're -- the worst thing is, in
`09:13:08
`neither the Bunker application nor the '568 patent,
`09:13:12
`are there ever end views showing, which would
`09:13:17
`show -- which would clarify what the shape is.
`09:13:20
`Neither one of them show what their shape is,
`09:13:22
`actually.
`09:13:25
` Q. Why would you need to see the end views to
`09:13:26
`have a better understanding of --
`09:13:31
` A. So a shape is defined by three views; not
`09:13:33
`two, and not one, like most of theirs show. And as
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`UTC-2003.013
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`14
`stated in your response, this shape is important in
`09:13:43
`these holes.
`09:13:46
` And the -- the shape is neither defined
`09:13:48
`by -- completely by Bunker, nor by Kohli, in
`09:13:50
`their -- Bunker's patent application and the '568
`09:13:57
`patent do not define the shape.
`09:14:00
` So I -- could I get some water, please.
`09:14:03
` Q. Grab your microphone, sir.
`09:14:32
` A. Thank you.
`09:14:32
` I lost my -- you were asking about
`09:14:32
`ambiguity of the drawings; right?
`09:14:34
` Q. Yes, sir.
`09:14:36
` A. And I think that cross-sections are crucial
`09:14:36
`to understand.
`09:14:40
` And so what I did was look at the pictures
`09:14:40
`as drawn in the patent, '568, and in Bunker's
`09:14:43
`application, and used my engineering judgment and
`09:14:48
`experience with film cooling holes to -- to make
`09:14:53
`a -- my engineering judgment on what they were
`09:14:58
`attempting to draw.
`09:15:00
` Some of the things in my own sketch notes
`09:15:02
`that I reviewed last night -- I should have said I
`09:15:07
`also reviewed my own notes from when I reviewed all
`09:15:11
`these things. I have written down, "I don't know
`09:15:14
`what this is trying to draw here."
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`Henderson Legal Services, Inc.
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`UTC-2003.014
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`15
` Q. Do you recall any specific examples?
`09:15:18
` A. Yeah. One example is the '568 patent has
`09:15:20
`these four different trapezoids in the center
`09:15:25
`between the two lobes, and it's unclear at all what
`09:15:30
`those are supposed to be. It's not well defined in
`09:15:33
`the text or the -- or the -- or the claims or the
`09:15:37
`other drawings.
`09:15:45
` Q. What about with respect to Bunker, any
`09:15:46
`specific ambiguities there as well?
`09:15:49
` A. So the -- the ambiguity that I don't like
`09:15:52
`is that I remember the -- I believe it's line 80 on
`09:15:57
`the back is not entirely clear what -- it's on the
`09:16:00
`upstream side of the breakout. And I think I
`09:16:04
`understand what that is now, but I've been do --
`09:16:07
`learning that by studying a lot of other pictures
`09:16:11
`of film cooling holes. So I don't think -- I don't
`09:16:14
`think, reading that patent or looking at the
`09:16:20
`pictures in it, that it's clear what that line is.
`09:16:23
` Q. So you were looking at other pictures of
`09:16:26
`film cooling holes, you just said. Were those
`09:16:31
`pictures that are not cited in your declaration, is
`09:16:36
`that what you're referring to?
`09:16:40
` A. No, I don't think they're cited in my
`09:16:43
`declaration. I was look -- I was looking at
`09:16:47
`pictures on the web and pictures in my own book,
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`UTC-2003.015
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`16
`things like that, to try to see what they would
`09:16:57
`be -- look like in that view.
`09:17:01
` I also looked at a couple of real turbine
`09:17:05
`blades yesterday, too.
`09:17:08
` Q. For the real turbine blades, do you know
`09:17:16
`from what product they came from?
`09:17:20
` A. You know, one is an experimental blade that
`09:17:21
`I can't reveal what product it would be for.
`09:17:25
` Another one was from a International Aero
`09:17:28
`Engines. I'm not sure of the exact model, but it's
`09:17:31
`off of a 737, so it's -- it's old.
`09:17:37
` Q. Did you choose those two --
`09:17:47
` A. They are things I have.
`09:17:49
` Q. So you selected those two turbine blades to
`09:17:58
`look at yourself?
`09:18:01
` A. Just because they're the two I have. And
`09:18:02
`they have diffuser holes in them. I wanted to see
`09:18:04
`what the diffuser hole breakout looked like in that
`09:18:06
`top view.
`09:18:09
` Q. How large are the holes on the --
`09:18:13
` A. Small.
`09:18:17
` Q. -- on the experimental blade, for example?
`09:18:18
` A. A few millimeters.
`09:18:20
` Q. Did you need to use some form of
`09:18:22
`magnification?
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`UTC-2003.016
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`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`17
` A. I did, yeah.
`09:18:27
` Q. Is the same true for the 737 --
`09:18:28
` A. Yeah.
`09:18:31
` Q. -- turbine blade?
`09:18:31
` A. Same size. They're both blades for the
`09:18:31
`same-size engines.
`09:18:35
` Q. For the photos of cooling holes that you
`09:18:36
`looked at, do you recall any in particular that you
`09:18:39
`looked at?
`09:18:41
` A. So the Penn State University turbo
`09:18:41
`machinery lab has a generic diffuser hole that they
`09:18:47
`encourage the community to use, and they have a
`09:18:51
`good drawing of it on -- on their website. I
`09:18:53
`looked at that last night and tried to think about
`09:18:56
`how that would be reflected on the -- on the
`09:18:58
`surface.
`09:19:02
` And I -- my particular thing was the
`09:19:03
`upstream edge of the breakout nuts. All of these
`09:19:04
`designs is similar to a standard hole. There's no
`09:19:09
`mention of a change there in any -- they all have
`09:19:12
`a -- a line that goes straight from the metering
`09:19:14
`section as both -- all of Bunker and '568 both show
`09:19:18
`the straight line at -- that comes from the
`09:19:25
`metering hole, the top of the metering hole out to
`09:19:28
`the breakout, up to the upstream end of the
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`UTC-2003.017
`
`

`

`Eaton, John
`
`IPR2016-00862
`
`December 20, 2016
`
`18
`breakout. And so I thought well, all these are
`09:19:34
`going to look the same up there, so ...
`09:19:36
` Q. You mentioned looking at that last night;
`09:19:39
`is that right?