Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________
` TOYOTA MOTOR CORPORATION and AISIN SEIKI CO., LTD.,
` Petitioners,
` v.
` INTELLECTUAL VENTURES II LLC,
` Patent Owner.
` _________________________
` Case IPR2017-01495
` Patent 7,928,348 B2
` Washington, D.C.
` Wednesday, June 13, 2018
` Deposition of CHARLES ALEXANDER GARRIS,
`JR., PH.D., a witness herein, called for examination
`by counsel for Petitioners in the above-entitled
`matter, pursuant to notice, the witness being duly
`sworn by KAREN YOUNG, a Notary Public in and for the
`District of Columbia, taken at the offices of Knobbe
`Martens, 1717 Pennsylvania Avenue, Northwest, Suite
`900, Washington, D.C., at 9:33 a.m. on Wednesday,
`June 13, 2018, and the proceedings being taken down
`by stenotype and transcribed by KAREN YOUNG.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 1
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
`2
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________
` AISIN SEIKI CO., LTD., TOYOTA MOTOR CORP., and
` AMERICAN HONDA MOTOR CO., INC.,
` Petitioners,
` v.
` INTELLECTUAL VENTURES II LLC,
` Patent Owner.
` _________________________
` Case IPR2017-01538
` Patent 7,928,348 B2
`
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 2
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
`3
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________
` AISIN SEIKI CO., LTD., TOYOTA MOTOR CORP., and
` AMERICAN HONDA MOTOR CO., INC.,
` Petitioners,
` v.
` INTELLECTUAL VENTURES II LLC,
` Patent Owner.
` _________________________
` Case IPR2017-01539
` Patent 7,683,509 B2
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 3
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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`APPEARANCES:
` On Behalf of Toyota Motor Corporation:
` ALYSSA J. HOLTSLANDER, ESQ.
` Finnegan, Henderson, Farabow,
` Garrett & Dunner, LLP
` Two Freedom Square
` 11955 Freedom Drive
` Reston, Virginia 20190-5675
` ALYSSA.HOLTSLANDER@FINNEGAN.COM
` (571) 203-2700
`
` JOSHUA L. GOLDBERG, ESQ.
` Finnegan, Henderson, Farabow,
` Garrett & Dunner, LLP
` 901 New York Avenue, Northwest
` Washington, D.C 20001-4413
` JOSHUA.GOLDBERG@FINNEGAN.COM
` (202) 408-4000
`
` On Behalf of Aisin Seiki Co., Ltd.:
` ALEXANDER B. ENGLEHART, ESQ.
` Oblon, McClelland,
` Maier & Neustadt, L.L.P.
` 1940 Duke Street
` Alexandria, Virginia 22314
` aenglehart@oblon.com
` (703) 413-3000
`
` On Behalf of American Honda Motor Co., Inc.:
`
` LI GUO, ESQ.
` Steptoe & Johnson LLP
` 1330 Connecticut Avenue, Northwest
` Washington, D.C. 20036-1795
` lguo@steptoe.com
` (202) 429-1322
`
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 4
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
`5
`
` On Behalf of Intellectual Ventures II LLC:
` BRENTON R. BABCOCK, ESQ.
` Knobbe Martens
` 2040 Main Street, 14th Floor
` Irvine, California 92614
` brent.babcock@knobbe.com
` (949) 760-0404
`
` ALSO PRESENT:
` James R. Hietala, Intellectual Ventures
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 5
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
`6
`
` C O N T E N T S
`THE WITNESS:
`CHARLES ALEXANDER GARRIS, JR., PH.D.
` By Ms. Holtslander......................... 8
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 6
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
`7
`
` E X H I B I T S
`EXHIBIT NO. PAGE NO.
`Exhibit 1136 Expert Report of Dr. Hamid A. Toliyat..18
`Exhibit 1137 Figure 1 from U.S.
` Patent No. 2,951,650.................. 42
`
`
` PREVIOUSLY MARKED EXHIBITS
`EXHIBIT NO. PAGE NO.
`Exhibit 1003 Japanese Unexamined Patent Application
` Publication H10-23891............... 53
`Exhibit 1008 U.S. Patent No. 4,944,748.............47
`Exhibit 1103 U.S. Patent No. 3,117,526.............27
`Exhibit 1105 U.S. Patent No. 2,951,650.......... .42
`Exhibit 2005 Copy of Book, "Plastics, Materials
` and Processing" by A. Brent Strong... 37
`Exhibit 2009 Declaration of Dr. Charles A. Garris,
` Jr. in Support of Patent Owner's
` Response, IPR2017-01495............. 26
`Exhibit 2010 Declaration of Dr. Charles A. Garris,
` Jr. in Support of Patent Owner's
` Response, IPR2017-01538............. 49
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`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 7
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` P R O C E E D I N G S
`Whereupon,
` CHARLES ALEXANDER GARRIS, JR., PH.D.,
` residing at 2125 Twin Mill Lane, Oakton,
` Virginia, called for examination by counsel
` for Toyota Motor Corporation, and having
` been duly sworn by the Notary Public, was
` examined and testified as follows:
` - - -
` EXAMINATION BY COUNSEL FOR TOYOTA MOTOR CORPORATION
` BY MS. HOLTSLANDER:
` Q. Good morning, Dr. Garris. Could you please
`state your full name and address for the record?
` A. Sure. Charles Alexander Garris, Junior,
`2125 Twin Mill Lane, Oakton, Virginia 22124.
` Q. Thank you. And do you understand that
`you're under oath this morning?
` A. I do.
` Q. And that that means you're sworn to tell
`the truth as if you were in a courtroom with a judge
`and a jury?
` A. Yes, ma'am.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 8
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` Q. And there's nothing that will prevent you
`from giving me full and truthful answers today?
` A. No, there is not.
` Q. If you don't understand any of my
`questions, can you please ask me to clarify?
` A. Yes, ma'am.
` Q. And is it fair for me to assume that if you
`answer a question, that you understood it?
` A. Well, I think it's fair -- fair to assume
`that. I'll do my best to make sure that that's the
`case.
` Q. And we'll try and take a break every 60
`minutes or so, but before we take a break, if there's
`a question pending, I would just like you to answer
`that question. And also, if there's any time where
`you need to take a break, please let me know, but
`again, if there's a question pending, please answer
`that question. Is that all acceptable to you?
` A. Sounds good.
` Q. Okay. And during breaks, you may not
`discuss the substance of your testimony with IV's
`counsel, okay?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 9
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` A. Yes, I've been advised that.
` Q. Have you ever been deposed before?
` A. Yes, ma'am.
` Q. And how many times have you been deposed?
` A. I really don't keep track of it, but quite
`a few. Numerous times.
` Q. Do you think more than 50 times?
` A. Yes.
` Q. More than a hundred times?
` A. I don't know. It's definitely more than
`50.
` Q. More than 50? More than 75?
` A. You're -- you're asking me to speculate --
` Q. Okay.
` A. -- and guess, but I think you can kind of
`figure it out from looking at my -- my resume. You
`know, I have a list of all the cases I've been in,
`and most of those cases I've been deposed at least
`once, so -- and in some cases more than once, so add
`them up, it comes out to somewhere between 75 and a
`hundred.
` Q. Okay. And when was the last time you were
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 10
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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`deposed?
` A. I think probably about six months ago.
` Q. And what case was that?
` A. That was a -- that was a case with Blank
`Rome on -- in New York, in Manhattan. I was
`basically involved, stage -- stage machinery, winches
`and devices like that.
` Q. Was that an IPR proceeding or litigation?
` A. Litigation.
` Q. Litigation. You understand that today
`we're here to discuss declarations that you prepared
`related to U.S. patent number 7,928,348 and U.S.
`patent number 7,683,509; is that correct?
` A. Yes, ma'am.
` Q. And is it okay with you if I refer to U.S.
`patent number 7,928,348 as the '348 patent?
` A. That'd be helpful.
` Q. And U.S. patent number 7,683,509 as the
`'509 patent?
` A. That'd be great.
` Q. Excellent. Specifically you prepared two
`declarations related to the '348 patent, correct?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 11
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
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` A. Yes.
` Q. And those declarations were in
`IPR2017-01495 and IPR2017-01538, correct?
` A. Correct, yes.
` Q. And you prepared one declaration related to
`the '509 patent, correct?
` A. Correct.
` Q. And that declaration was in IPR2017-01539,
`correct?
` A. Yes.
` Q. Thank you. When were you first contacted
`to assist on these matters?
` A. You know, I did not check my -- my records
`before the deposition, so I'm going by memory, and be
`perfectly honest, I'm not really good at fixing time.
`You know, time seems to go by, but I would guess --
`and again, the records may show very different, but
`the -- I would guess probably around January or so.
` Q. Around January of --
` A. Of 2018.
` Q. -- 2018?
` A. Or it might have been before Christmas,
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 12
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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`somewhere around then I believe.
` Q. Sometime in winter of the 2017 --
` A. I believe so, yes.
` Q. -- to 2018? Thank you. And when did you
`first receive the '348 and '509 patents to review?
` A. I think probably around the same time.
`Yeah, more or less the same time. Basically I was
`sent a -- an abundance of material, including the
`patents.
` Q. So again, in winter of 2017-2018 --
` A. Yes.
` Q. -- time frame? And did you write your
`declaration for IPR2017-01495?
` A. Well, I mean, I wrote large parts of it.
`You know, I mean, I worked with the attorneys. They
`produced the draft of the -- you know, a draft
`declaration, and I -- I supplemented it and amended
`it and deleted things, and so it is my -- it is my
`declaration, but the attorneys certainly helped me in
`coming up with the final draft.
` Q. Is that the same answer for IPR2017-01538
`and IPR2017-01539?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 13
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` A. Yes, ma'am.
` Q. How many hours did you spend preparing your
`declaration in IPR2017-01495?
` A. I would say it's -- sometimes it's a little
`hard to quantify because there's overlapping among
`the different IPRs, you know, different -- you know,
`the patents are the same and, you know, which one do
`I charge the patent, reviewing the patent, you know,
`and the prior art is different for the two IPRs, but
`I would probably say about 30, 40 hours for each IPR.
` Q. Thirty, 40 hours for each of the
`declarations --
` A. Yes.
` Q. -- you prepared in these three cases?
` A. Yes, ma'am.
` Q. Does that include the time you spent
`reviewing the prior art?
` A. Yes.
` Q. And did you talk to anyone in preparing any
`of your declarations?
` A. Well, yes, yes, I was working with counsel.
` Q. And who did you speak with?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 14
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` A. Well, in terms of these -- these
`declarations, I primarily spoke with Dave Jankowitz.
` Q. And he's counsel for IV?
` A. Yes.
` Q. Outside of counsel for IV, did you speak to
`anyone else?
` A. No, no, I did not.
` Q. Do you know a Dr. Joseph Beaman?
` A. Well, I'm familiar with the fact that he's
`an expert on the '509 -- '509 IPR, and I read some of
`his -- his declaration, but --
` Q. Did you speak with him at all?
` A. No, I never did.
` Q. Did you review any declarations prepared by
`Dr. Beaman?
` A. I did not really -- I did not review his
`declaration at all, but I did review -- I was given
`excerpts of it. You know, there were a couple of --
`a couple excerpts from it, you know, on -- on a
`person of ordinary -- his definition of a person of
`ordinary skill in the art, and there was a portion of
`his declaration where he talked about the field of
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 15
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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`the invention, which is really just taking that from
`the top of the patent, you know. So they -- they --
`they told me that these were included in his report
`and asked if I agreed with it, and of course, I did
`review the patent itself.
` Q. Was that a excerpt of a final version of
`his declaration or a draft of his declaration?
` A. I'm not sure. I'm not sure, but I would
`tell you that it was very close to the deadline where
`the declarations had to be submitted, so I -- I -- I
`have no way of knowing whether the declaration was
`changed after I saw those excerpts, but my -- my
`understanding was that it was -- it was not. You
`know, it wouldn't make sense to get me to say that I
`agree to some excerpts and then go ahead and change
`those excerpts in the declaration, so I don't think
`that happened.
` Q. Okay. Was there anything in the excerpt of
`the declaration that you disagree with?
` A. No, no, I think they were -- both of the
`excerpts that were showed to me were pretty -- pretty
`-- pretty general.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 16
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` Q. And did you review any other declarations
`by Dr. Beaman?
` A. No, I did not.
` Q. Do you know a Dr. Hamid Toliyat?
` A. No, no, I do not.
` Q. Did you review any declarations or reports
`prepared by a Dr. Hamid Toliyat?
` A. Not that I recall.
` Q. When did you start preparing for this
`deposition?
` A. Well, I think I started preparing for this
`deposition basically the day before yesterday. I
`guess on Monday.
` Q. And how many hours did you spend preparing
`for this deposition?
` A. I would say about 15.
` Q. Did you talk to anyone in preparing for the
`deposition?
` A. Yes, I did.
` Q. And who did you speak with?
` A. Well, I spoke with Mr. Jankowitz. He was
`on -- by telephone, he telephoned in, and I -- I
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 17
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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`spoke with, you know, Brent Babcock and James as well
`from -- from IV.
` Q. Did you talk to anyone else?
` A. No, I did not.
` Q. Did you talk with Dr. Beaman at all in
`preparation for the deposition?
` A. No, ma'am, I've never talked to Dr. Beaman.
` Q. Thank you. Do you know the inventor of the
`'348 and '509 patents, Griffith Neal?
` A. No, I do not.
` Q. Are you aware that there's a co-pending ITC
`case in this matter, ITC being International Trade
`Commission?
` A. I've heard -- I've heard that, but I can't
`say I'm familiar with the specific details, but I
`have heard that.
` (Exhibit 1136
` was marked for
` identification.)
` BY MS. HOLTSLANDER:
` Q. I'm handing you a document that's titled
`"Expert Report of Dr. Hamid A. Toliyat," and I marked
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 18
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
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`it as Petitioner Exhibit 1136 in IPR2017-01495,
`IPR2017-01538 and IPR2017-01539.
` MR. BABCOCK: Just to clarify, this is
`already an exhibit in the IPRs or it is not?
` MS. HOLTSLANDER: It is not.
` MR. BABCOCK: All right. What number did
`we give it?
` BY MS. HOLTSLANDER:
` Q. 1136. Have you seen this document before?
` A. No, I have not.
` Q. Could you please turn to paragraph 1 of the
`document please, let me know when you're there.
` A. Yes, ma'am.
` Q. Thank you. It states that the asserted
`patents in this case are U.S. patent numbers
`7,154,200 as well as the '348 patent and the '509
`patent that are involved in the current IPRs that we
`are discussing, correct?
` A. That is correct.
` Q. Could you please now turn to paragraphs 26
`to 27?
` A. Okay.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 19
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
`
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` Q. At the beginning of paragraph 27,
`Dr. Toliyat states that a person of ordinary skill in
`the art for the asserted patents would have a degree
`of electrical engineering, mechanical engineering,
`materials engineering, manufacturing engineering
`and/or a related field. Do you see that?
` A. Yes, ma'am.
` Q. Do you agree with this portion of the
`definition provided by Dr. Toliyat?
` A. Well, I -- I believe that -- I mean, I
`think -- I don't -- it's not -- it's not the same as
`-- as my definition of a person of ordinary skill in
`the art. You know, I don't think a person with a
`degree in electrical engineering or materials
`engineering would necessarily -- or manufacturing
`engineering would necessarily have the skills needed
`for -- now, one -- one point is that -- that he's --
`he's defining the -- the person of ordinary skill in
`the art for -- for three patents, this '200 patent,
`which I'm totally not familiar with, so I can't speak
`to what skills in the art might be necessary for
`that.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 20
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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` So I think he's trying to talk about a
`person -- his definition of a person of skill in the
`art seems to be very -- seems to encompass several
`fields that are somewhat different, and he seems to
`be putting an umbrella over -- you know, over the
`three patents, one of which I'm not familiar with,
`but I -- I mean, this is not -- not what I -- the way
`I would define a person of ordinary skill in the art.
` Q. So you said a person having an electrical
`engineering degree, a materials engineering degree
`and a manufacturing engineering degree would not
`necessarily meet the requirements for a person of
`ordinary skill in the art, correct?
` A. Not necessarily. I mean, they might. You
`know, it all -- it all depends on, you know, what
`aspects of -- you know, material -- all these types
`of engineering are very -- can be very, very
`specialized. You know, so one can get a degree in
`electrical engineering without ever seeing a motor,
`you know? One can get a degree in materials
`engineering without ever seeing any -- an injection
`molded product, you know? So -- so the definition
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 21
`Aisin Seiki v. Intellectual Ventures
`IPR2017-01539
`
`

`

`Case IPR2017-01495; IPR2017-01538; IPR2017-01539
`Garris, Jr., Ph.D., Charles Alexander
`June 13, 2018
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`here is -- is a little bit -- a little bit -- a
`little bit vague, you know.
` He doesn't have -- another thing that I
`would find inconsistent with mine -- oh, well, no,
`no, on the other hand, he goes on to say that such a
`person would also have at least three -- three years
`of experience in the field of designing and/or
`manufacturing electromagnetic motors involving one or
`more components, so he does go on and he says that
`people would have additional -- you know, additional
`experience.
` I wouldn't disagree with what he says. You
`know, a person who has a degree in materials
`engineering but has three years of practical
`experience in -- in electric motor design, you know,
`probably would have -- would be a person of ordinary
`skill in the art. You know, I wouldn't say that
`having a degree in materials engineering would
`necessarily disqualify a person. It would be
`helpful. So I wouldn't disagree with what he says.
`It's just that -- it's -- I think it's somewhat
`broader than -- than what I defined it as.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Aisin Seiki Exhibit 1016, pg. 22
`Aisin Seiki v. Intelle