`
`Date: June 22, 2018
`Case: Cascades Canada ULC -v- Essity Professional Hygiene North America LLC
`(PTAB)
`
`Planet Depos
`Phone: 888.433.3767
`Email:: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING | INTERPRETATION | TRIAL SERVICES
`
`ESSITY EXHIBIT 2009
`Cascades v. Essity, IPR2017-02198
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CASCADES CANADA ULC,
`
`Petitioner,
`
`
`vs.
`
`ESSITY PROFESSIONAL
`HYGIENE NORTH AMERICA,
`LLC,
`
`
`Patent Owner.
`
`)
`)
`)
`)
`) Case IPR2017-02198
`)
`) Patent 8,273,443 B2
`)
`)
`)
`)
`
`DEPOSITION OF MATE MRVICA
`TAKEN ON BEHALF OF THE PATENT OWNER
`JUNE 22, 2018
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`2
`
` I N D E X
` WITNESSES
`ALL WITNESSES PAGE
`For Patent Owner
` MATE MRVICA
` Examination by Mr. Mancino 7
` Examination by Ms. Fussner 138
` Re-Examination by Mr. Mancino 147
`
` EXHIBITS
`NO. DESCRIPTION PAGE
`Exhibit 1001 United States Patent
` No. US 8,273,443 B2 86
`Exhibit 1002 Declaration 11
`Exhibit 1003 Curriculum Vitae 99
`Exhibit 1004 Note 34
`Exhibit 1016 United States Patent
` No. US 6,602,575 B2 29
`Exhibit 1017 Note pertaining to nine
` panel napkin 30
`Exhibit 1018 ASTM Standard
` Specification for Paper
` Napkins for Industrial and
` Institutional Use 69
`Exhibit 1021 United States Patent
` No. US 6,699,360 B2 117
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
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`3
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` EXHIBITS
`NO. DESCRIPTION PAGE
`Exhibit 1022 S. Wheeler, Paper
` Package and Process of
` Forming Same, 1,430,709,
` Patented Oct. 3, 1922 117
`
`Exhibit 2001 4/12/18 Transcript of
` Mate Mrvica 11
`Exhibit 2002 4/13/18 Transcript of
` Mate Mrvica, Volume 2 11
`Exhibit 2003 4/26/18 letter Re:
` 4/12/18 Mate Mrvica
` deposition with
` corrections 11
`Exhibit 2004 4/28/18 letter Re:
` 4/13/18 Mate Mrvica,
` Volume 2, deposition
` with corrections sheet 11
`Exhibit 2005 Declaration of Mate
` Mrvica in Support of
` Petition for Inter
` Partes Review of US
` Patent No. 8,273,443 19
`Exhibit 2006 United States Patent
` No. US 9,017,790 B1 132
`
`(Exhibits attached to transcript.)
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`4
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRIAL AND APPEAL BOARD
`
`CASCADES CANADA, ULC, )
` )
` Petitioner, )
`
`
`)
`vs.
`) Case IPR2017-02198
` )
`ESSITY PROFESSIONAL ) Patent 8,273,443 B2
`HYGIENE NORTH AMERICA, )
`LLC, )
`
`
`)
`Patent Owner.
`)
`
`DEPOSITION OF WITNESS, MATE MRVICA,
`produced, sworn and examined on the 22nd day of
`June, 2018, between the hours of eight o'clock in
`the forenoon and six o'clock in the afternoon of
`that day, at the offices of Husch Blackwell, 190
`Carondelet Plaza, Suite 600, St. Louis, Missouri,
`before Tara Schwake, a Registered Professional
`Reporter, Certified Realtime Reporter, Certified
`Shorthand Reporter (IL), Certified Court Reporter
`(MO), and Notary Public within and for the State of
`Missouri.
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`5
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`APPEARANCES
`FOR THE CLAIMANT:
` HUSCH BLACKWELL, LLP
` 190 Carondelet Plaza, Suite 600
` St. Louis, Missouri 63105
` (314) 480-1500
` by: Ms. Kara Fussner
` kara.fussner@huschblackwell.com
`FOR THE PATENT OWNER:
` BAKER & HOSTETLER
` 312 Walnut Street, Suite 3200
` Cincinnati, Ohio 45202
` (513) 929-3496
` by: Mr. David A. Mancino
` dmancino@bakerlaw.com
`INTERPRETERS:
` Ms. Lily Olm
` Ms. Louise DiMarco
`ALSO PRESENT:
` Mr. Pierre Brochu
` VP Legal Affairs, Cascades Tissue Group
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`6
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`ALSO PRESENT:
`Mr. Ramon Urteaga
`Regional IP Counsel
`Essity North America, Inc.
`
`Ms. Tara Schwake, CRR, RPR, CCR, CSR
`On Behalf of Planet Depos
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`7
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` IT IS HEREBY STIPULATED AND AGREED by
`and between Counsel for all parties that this
`deposition may be taken by Tara Schwake, Notary
`Public and Certified Realtime Reporter, thereafter
`transcribed into typewriting, with the signature of
`the witness being expressly reserved.
` MATE MRVICA,
`of lawful age, having been produced, sworn, and
`examined on the part of Patent Owner, testified as
`follows:
` * * * * *
` (Deposition commenced at 8:08 a.m.)
` (Any French conversations between witness
`and interpreter are not reflected in the
`transcript.)
` EXAMINATION
`QUESTIONS BY MR. MANCINO:
` Q Good morning, Mr. Mrvica. Nice to
`see you again.
` A Okay.
` Q As you recall from our prior
`deposition, my name is David Mancino, and I am one
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`Conducted on June 22, 2018
`
`8
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`of the attorneys representing Essity with respect
`to these inter partes reviews and specifically the
`inter partes review we will be discussing today.
` And do you recall I took your
`deposition on April 12 and 13 in St. Louis? In
`this same room?
` A Same room, same place, same chair.
` Q And that deposition concerned inter
`partes review for the '761 patent and the '372
`patents?
` A Yes.
` Q And I notice we're not getting
`interpretation as we go along. You are right.
`Because it's not technical. That's why.
` MS. FUSSNER: As soon as he asks the
`question, just start saying it in French and then,
`Mate --
` A I remember last time it was difficult
`sometime to follow.
` (Off the record.)
` Q (BY MR. MANCINO) For the record,
`today's deposition concerns inter partes review
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`Conducted on June 22, 2018
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`9
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`number IPR201-02198. It is an inter partes review
`of US Patent No. 8,273,443. The Petitioner is
`Cascades Canada ULC and the Patent Owner is Essity.
`Okay?
` So as a reminder for I guess basic
`ground rules for the deposition, I will ask you
`questions and your questions may or may not be
`interpreted by an interpreter.
` If you do not understand my question,
`please let me know and we'll try to work with you
`to phrase it in a way that you do understand it.
`Is that okay?
` A Mm-hmm. Yes.
` Q If you do provide an answer to my
`question, I'm going to assume that you fully
`understood my question. Is that fair?
` A Yes.
` Q We only have one day for today's
`deposition per agreement. I'm going to, I think --
`is there any stop time that I need to know about?
` MS. FUSSNER: We'd like to be done no
`later than 5:00.
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`MR. MANCINO: Okay.
`Q (BY MR. MANCINO) With respect to
`that, you can take breaks at any time that you need
`them or that you think you need a break or anybody
`needs a break. Just let me know. And if I have a
`line of questioning, I'll try to finish that line
`of questioning before the break but this is -- this
`is not an endurance challenge.
`So if at any time you feel tired or
`need to take a break, just let me know.
`A Okay. Thank you.
`Q Are there any circumstances or
`reasons that would prevent you today from answering
`my questions fully and truthfully?
`A No.
`Q Do you understand why you are here
`
`today?
`
`Absolutely.
`A
`What is your understanding?
`Q
`That I got a good practice last time,
`A
`it was the first time, and we saw that there's
`another patent and I am here to debate some aspect
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`11
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`of this patent. (Speaking French).
`Q I'm going to introduce a couple of
`new exhibits. The first one is marked as Exhibit
`2001. Should be marked as Exhibit 2001.
`(Exhibit 2001 marked for
`identification by the court reporter.)
`MR. MANCINO: And then I'm going to
`hand you we're going to mark this one as Exhibit
`2002.
`
`(Exhibit 2002 marked for
`identification by the court reporter.)
`MR. MANCINO: Two more. This one
`will be marked as 2003.
`(Exhibit 2003 marked for
`identification by the court reporter.)
`MR. MANCINO: And then the next one
`will be marked as Exhibit 2004.
`(Exhibit 2004 marked for
`identification by the court reporter.)
`MR. MANCINO: Okay. And then
`finally, for this stage, I'm going to hand you what
`has previously been marked as Exhibit 1002.
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`12
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` Q (BY MR. MANCINO) Okay. First, Mr.
`Mrvica, can you turn your attention to the exhibit
`that is marked as Exhibit 1002?
` MS. FUSSNER: David, he brought a
`copy of his Declaration in the binder to make it
`easier for him this time. Do you want to see it?
` A And the -- you got the patent even
`the '443 in the back.
` MR. MANCINO: Okay. Are there any
`writings or notes or anything like that on there?
` MS. FUSSNER: Just some highlighting?
` A I write and --
` MS. FUSSNER: I can make you a copy
`of it if you want.
` MR. MANCINO: Let's go ahead and make
`a copy of that in color and we'll mark that as
`another exhibit. So 2005?
` MS. FUSSNER: Yep.
` (Off the record.)
` Q (BY MR. MANCINO) So turning to what
`is currently marked as Exhibit 1002, Mr. Mrvica,
`please take your time to review that and let me
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`13
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`know when you're ready.
` A Review the document? Just to look at
`it?
` Q Primarily to make sure that you
`understand what it is.
` A Okay. I think I review it the last
`couple of days, so.
` Q What is this document?
` A It's to say that, Declaration that
`says, you know, that there was prior art, you know,
`on the '443 patent of SCA, there was a lot of
`element exist former from the patent of the '443.
` Q What type of document is this?
` A So it's his Declaration that there
`were many elements of prior art prior to the patent
`'443.
` Q Do you understand what a Declaration
`is?
` A Yes.
` Q What is your understanding?
` A So it's a document that demonstrates
`his understanding of techniques that existed prior
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`14
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`to this -- or in prior art and so it's a reading of
`documents that established those techniques and
`proved that they existed prior to the patent.
` Q Looking at this document, do you --
`are you able to recognize which proceeding this
`document pertains to?
` A So if you look at the Table of
`Contents, it outlines everything that this pertains
`to, in particular the patent of '443.
` It describes the elements in summary
`of prior art which existed before '443 in the
`chapters in the Table of Contents with elements and
`material.
` MR. BROCHU: Feel free to interrupt
`if you need, because the responses are long. Sorry
`to interrupt.
` Q (BY MR. MANCINO) In looking at this
`document, Exhibit 1002, do you understand which
`patent this Declaration pertains to?
` A Yes.
` Q And can you identify it?
` A So patent number 8,273,443.
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`15
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` Q And it says at the bottom, bold
`faced, all caps, paragraph, "Declaration of Mate
`Mrvica in support of Petition for Inter Partes
`Review of US Patent No. 8,273,443."
` Do you see that?
` A Yes.
` Q What does that mean?
` A It's the Declaration having been made
`to demonstrate that '443 existed with elements of
`prior art.
` Q Is it your understanding that today's
`deposition concerns your testimony that appears in
`Exhibit 1002?
` A He is here to demonstrate that all of
`the elements that appear in '443 existed before.
`Before 2003.
` MS. FUSSNER: So the record I guess
`should say I am here to demonstrate instead of he
`is here to demonstrate.
` Q (BY MR. MANCINO) My question is, I
`want to -- I'll repeat my question. Is it your
`understanding that today's deposition concerns your
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`testimony as set forth in Exhibit 1002?
` A Yes.
` Q If you turn to page 4 of 58 in
`Exhibit 1002, please? In the second full
`paragraph, the second sentence, it says, "While the
`'443 patent lists different inventors and is not in
`the same patent family as the '761 and '372
`patents, the subject matter substantially
`overlaps."
` Do you see that?
` A Yes.
` Q Is that your opinion?
` A Yes.
` Q Specifically what subject matter
`overlaps between the '761, '372 patents, and the
`'443 patent?
` A The '443 patent is really a link to
`six-panel interfold, and the other two patent were
`really on the offset aspect.
` Q Okay. But that answer appears, to me
`at least, to be the technology that does not
`overlap. My question is, what subject matter does
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`overlap with respect to these?
` A I can -- we can -- I can -- I can
`include, or I can bring elements from '443 that
`overlap with '761 and '372.
` Q What elements come to mind currently
`that overlap?
` A Can be all of them. Well,
`essentially all of them, I can include the
`rectangular shape, their pattern, their embossment,
`the offset -- and I can name all the elements from
`prior art based from '761 and '372 to '443. So
`that's basic. That's basic.
` Q And you recall being deposed on April
`12 and 13 regarding your testimony with respect to
`the '761 and '372 patents; correct?
` A Yes.
` Q And so your testimony that you gave
`on April 12 and 13 is relevant to the subject
`matter for today's deposition; correct?
` MS. FUSSNER: Objection.
` A What I mean is it's not relevant at
`all because I can make a link between all the
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`patents, I can link each patent to another.
` Q (BY MR. MANCINO) So you're -- you
`have in your Declaration here that the subject
`matter of the patents overlap, but you're saying
`that your deposition testimony does not overlap?
` MS. FUSSNER: Objection.
` A I'll repeat in some places. I can
`repeat the same testimony, but for today, the
`testimony I give for '443 is for '443.
` Q (BY MR. MANCINO) Okay. My question
`is with respect to the overlapping subject matter.
`Is your testimony that you gave on April 12 and 13
`relevant?
` MS. FUSSNER: Objection. David, the
`board told us to be clear as to which proceeding we
`were talking about. So he can't make a decision as
`to whether something in that proceeding can come
`into this proceeding as a legal matter. The board
`told us to be clear on which one we're talking
`about. So I'm not even sure what you're asking.
` Q (BY MR. MANCINO) I'm asking about,
`in your Declaration you say that "the subject
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`matter substantially overlaps."
` MR. MANCINO: And to be clear, Kara,
`that is the specific and explicit subject matter
`that I'm asking about.
` Q (BY MR. MANCINO) And with respect to
`that subject matter that you listed in your own
`Declaration, is your deposition testimony relevant
`-- excuse me -- is your deposition testimony from
`April 12 and 13 still applicable?
` A Of course, yes, that's still
`applicable.
` Q And can we mark -- did -- can we mark
`that blue folder as Exhibit 2005?
` (Exhibit 2005 marked for
`identification by the court reporter.)
` Q (BY MR. MANCINO) Could you, Mr.
`Mrvica, could you explain for the record what has
`been marked as Exhibit 2005?
` A It's the main Declaration that Mr.
`Encino (sic) brought and it's a review of the inter
`partes '443. So at the end he also has the '443
`patent. So at the end of my Declaration, just to
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`be clear, I attached patent '443. That is the
`patent of Essity.
` Q Okay. And so this Exhibit 2005
`includes what appears to be marked up copies of
`Exhibit 2005 at the front, and a marked up copy of
`the '443 copy at the back; correct?
` MS. FUSSNER: I think you mis -- so
`this is 2005.
` MR. MANCINO: Let me -- you're right,
`Kara.
` Q (BY MR. MANCINO) So this Exhibit
`2005 appears to be marked up copies of Exhibit 1002
`at the front and a marked up copy of '443 patent at
`the back; correct?
` A Yes.
` Q Okay. This document also appears to
`have colored highlighting; correct?
` A Yes.
` Q And there are multiple colors. For
`example, I see yellow, green, pink, blue?
` A I am dyslexic, that's why.
` Q What does yellow mean?
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` A There is no particular legend or key.
`I have simply highlighted elements that I think
`will be important. There is no legend to the
`colors, whether they are red or yellow.
` Q So your answers may be -- so is it
`your answer that the different colors do not mean
`anything differently with respect to one another?
` A Well, maybe I try to differentiate
`some elements. So because there was so much
`material to cover, and maybe, for example, what is
`red, I checked some elements which were more
`important than others.
` Q So does the red highlight mean that
`it's more important as compared to a yellow
`highlight?
` A Well, you know, it is really not so
`adapt one thing is more important than another.
`The colors don't stand with regard to importance
`because everything is important. It's more a guide
`for me so that I have a reference line.
` Q Who made the highlighting marks in
`Exhibit 2005?
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`22
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` A I, myself.
` Q All of them?
` A Yes. And also written -- what is
`written in red, that's also my writing.
` Q Okay. So there are also written
`notes in the document. Are all of those written
`notes made by you?
` A Yes.
` Q With respect to the highlighted
`portions, when did you make the highlights?
` A Well, I made most of those highlights
`this week. Actually, I started when a date for
`this deposition was set but I finished with the
`highlighting this week.
` Q Did you make the highlights during
`your deposition preparations this week?
` A Well, yes, I think that's a normal
`way of doing things. During my preparation of the
`Declaration to point out the important elements,
`especially when a decisive date -- the date of the
`deposition comes close.
` And also just to be clear, I don't
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`23
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`have maybe the best memory and might not have such
`a good memory as Mr. Mancino.
` Q With respect to the highlighted
`portions, did you make them with counsel present?
` A Well, in the majority I would say 95
`percent, I guess, I did those highlighting myself,
`and then I added just a few additional items this
`past days, or this week.
` Q So is your answer that 95 percent of
`the highlightings were made outside of counsel, and
`the rest were made during preparations for your
`deposition with counsel?
` A Yeah, that's absolutely correct. I
`did most of the highlighting at home with a clear
`mind, a rested mind. In a zen state of mind.
` Q And why did you highlight this
`document 2005?
` A Well, I repeat again, I am a
`pragmatic, I am a practical, technical person. A
`person who works on equipment. And then when I
`have to deal with elements which are structured
`this way, I have to do a lot of reading, and then I
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`24
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`need some reference points.
` Q As you were -- and can you give me
`the time frame for the 95 percent of the
`highlighting that you made outside of the presence
`of counsel?
` A Well, maybe during the last two
`months.
` Q And as you were highlighting various
`sections of your Declaration as appears in Exhibit
`2005, were there any sections that you did not
`understand?
` A No. I answer that question with a
`no, where when I had interrogation points, I had
`department which helped me out, but this
`Declaration was already prepared in 2017.
` Q What do you mean, you said where you
`had --
` A Interrogation marks. Question marks.
` Q Oh, question marks, which -- who
`helped you out with your question marks?
` A Well, the legal department I am
`talking about.
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`25
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` Q So Cascades' legal department helped
`you out?
` A Cascades and the team at Kara. The
`team of Kara. Kara's team. sorry.
` Q So after -- in the two months that
`you said you made these highlights, you
`communicated with both in-house counsel and outside
`counsel regarding question marks that you had?
` A Yes.
` Q In what form were those
`communications?
` A Telephone. Well, many by telephone
`but then this week I was here and I spent a week
`here working with the attorneys.
` Q Do you recall what questions you had?
` A Well, I had, of course, several
`questions with regard to the documents which were
`linked, prior art documents which were attached to
`patent '443.
` Q Any other questions that you can
`recall?
` A Everything is linked to '443. Or
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`26
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`attached to '443.
` Q What -- when I asked before if you
`recall any questions you had about your Declaration
`as represented in Exhibit 2005, you answered that
`you had several questions with regard to the
`documents which were linked, and I asked you did
`you have any other additional questions beyond
`those.
` A So there are so many questions and
`now I'm thinking, what questions are you referring
`to? Questions over questions.
` Q For example, questions about what any
`of these paragraphs mean?
` A Well, for every kind of document you
`try to obtain more precision or clarification.
` Q Turn to page 9 of 58 in Exhibit 2005.
`Do you have 9 of 58? I'm going to try to stick
`with that numbering format on the bottom, 9 of 58.
`In the right-hand margin there is a note.
` Do you see that? What is that?
` A Well, that's my Declaration, 1002.
`So we went from 1001 to 1024.
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`27
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` Q So paragraph 16 says, "I have
`considered the following lists of materials in
`formulating my opinions in this matter."
` Do you see that?
` A Yes.
` Q And you wrote a note "1002
`Declaration" on the right-hand margin; right?
` A Yes.
` Q And so is -- did you intend to add
`that to the list, to this table?
` A No. It's only that I said to myself,
`well, obviously 1002 fits in here.
` Q And that's the only meaning for this
`note then; right?
` A Yes.
` Q Then on the next page, 10 of 58? In
`the left-hand column at the bottom -- excuse me,
`left-hand margin at the bottom, what is that note?
` A You mean the note which is outside of
`the table?
` Q In the left-hand margin at the
`bottom.
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`28
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` A Oh, you say left-hand, okay. I was
`looking at the right.
` Q What does that say?
` A Written in black?
` Q Yes.
` A "Can I get some sample?"
` Q What are you referring to with
`respect to that?
` A Of the '443 patent.
` Q So you are asking for a copy of the
`'443 patent?
` A No, I just wanted to see a physical
`sample.
` Q A physical sample of the subject
`matter covered by the '443 patent?
` A No, I just wanted to see if this
`product existed, in other words.
` Q Did you get a sample?
` A No.
` Q In the -- up above that in the table
`for, it appears Exhibit 1015, there is a note in
`red. What does that say?
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`29
`
` A What -- those are just reference,
`it's a reference mark for me. Those are elements
`which exist since tens and tens of years. Since
`decades.
` Q What is this note in the fifth row of
`the table on page 10 of 58? What does this note
`say?
` A You want me to read it?
` Q What does it say?
` A "Folder 6."
` Q And what does "Folder 6" mean?
` A It's a six-fold. Six-panel.
` Q So that means that the reference
`Exhibit 1015 is to a six-panel napkin?
` A Yes. That's my little tricks.
` Q I see. And then the next row. What
`does that note mean with respect to the '575
`patent, Exhibit 1016?
` A Four-panel, six-panel.
` Q So that's a note to yourself that the
`'575 patent for Exhibit 1016 pertains to a
`four-panel or six-panel napkin?
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`30
`
` A Yeah.
` Q And then the next note for Exhibit
`1017?
` A Six panels, nine panels.
` Q Okay. And with respect to these
`three notes for line 1015, 1016, and 1017, were
`these written in the presence of counsel, or
`outside of the presence of counsel?
` A No.
` Q No what?
` A I was alone.
` Q Okay. And then on line 1019, there
`is a note in the right-hand margin. What does that
`say?
` A "TAPPI ISO One Certification."
` Q So "TAPPI" is all caps, an acronym;
`correct? What are the letters?
` A It's a paper association of some
`methodology in the system of knowing the aspect.
` Q And the letters are T-A-P-P-I; is
`that right?
` A Yes.
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`31
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` Q And then "ISO" is I-S-O?
` A Yes.
` Q What does that stand for?
` A This would be registration for, you
`know, a standard norm in the business, quality
`aspect.
` Q And what are the notes below "ISO" in
`the right-hand column?
` A "One Certification."
` Q "One Certification"?
` A Yeah.
` Q And what does that mean?
` A This is a system that Cascades,
`Cascades have, we put in place from the past years
`that include ASTM, TAPPI, ISO. To provide process.
` Q Down in the row 1021, what is that
`note in the right-hand side of that row?
` A Same note as the "BW," basis weight,
`and "Ply," one-ply. Two-ply.
` Q So "BW Ply"; is that what it says?
` A So basis weight, or "BW," and the
`other aspect is just "Ply."
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`32
`
` Q And why did you write that?
` A To link, you know, there is so much
`prior art from the past that, to be sure that they
`can make the link.
` Q What is the note on the next line for
`1022?
` A "Interlink panels."
` Q What number is that on the right that
`you reference?
` A "3."
` Q And what does that stand for?
` A Three panels. So now you know my
`tricks.
` Q Turn to the next page, page 11 out of
`58. What is this note in the second line?
` A It's a "Reference."
` Q What does that mean?
` A A memo. No. Same word. The same as
`in English.
` Q Why did you write "Reference" there?
` A Well, I even underlined "rectangular
`paper napkin."
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`Transcript of Mate Mrvica
`Conducted on June 22, 2018
`
`33
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` Q Why?
` A Because this rectangular products
`have always existed.
` Q So the word "reference" means that
`this limitation has always existed?
` A So while for me it is a reference to
`indicate that this element existed since -- since
`moons. Since ever.
` Q Okay. If you go to page 13 of 58,
`there is a note in the first line of paragraph 26.
` Do you see that?
` A 13/58?
` Q Yes. Paragraph 26?
` A "Oriented"? Directed? "Oriented."
` Q So that note says "Oriented"?
` A Yeah. I can be a doctor.
` Q The next page, 14 of 58, what is this
`note at the bottom of