STC.UNM v. Intel Corporation

Filing 112

DECLARATION re 110 Brief of Brian Ferrall by Intel Corporation (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9)(Atkinson, Clifford)

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Page 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO No. 10-CV-01077 STC.UNM Plaintiff, vs. INTEL CORPORATION Defendant, Videotaped Deposition of STEPHEN D. HERSEE, Ph.D. April 26, 2011 9:00 a.m. 201 Third Street N.W., Suite 1800 Albuquerque, New Mexico PURSUANT TO THE APPLICABLE RULES OF CIVIL PROCEDURE this deposition was: TAKEN BY: BRIAN L. FERRALL Attorney for Intel Reported by: Marcia J. Schick, CM Hughes Southwest Court Reporters 110 2nd Street S. W. Suite 505 Albuquerque, New Mexico 87102 1 (Exhibit No. 7 - STC's Responses to Intel.) 2 Q So, we have marked as Exhibit 7 a document 3 entitled STC's Responses to Intel's Corporation Second Set 4 of Interrogatories, Nos. 30 to 32. Have you ever seen 5 this document, Dr. Hersee? 6 7 8 A I haven't seen this document but I believe I have seen an e-mail that contains this information. Q These Interrogatories request information about 9 the equipment used in the development of the 998 patent 10 and some other patents; right? Did you provide any 11 information regarding that equipment? 12 13 14 15 A I was asked to verify if this equipment was accurate and to the best of my knowledge, it is. Q So, your role was verifying, not actually identifying the equipment in the first place? 16 A Correct. 17 Q Does CHTM have the capability of manufacturing a 18 working integrated circuit? 19 A No. 20 Q What are the -- to the best of your knowledge, 21 22 what are the elements that are missing? A Well, that is a big question. Okay. There is a 23 whole design aspect that we don't have. We do have some 24 advanced lithography capabilities to make small features. 25 We don't really have beyond that any metallization Unsigned Page 31

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