STC.UNM v. Intel Corporation
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)
UNITED STATES DISTRICT COURT
DISTRICT OF NEW MEXICO
Videotaped Deposition of STEPHEN D. HERSEE, Ph.D.
April 26, 2011
201 Third Street N.W., Suite 1800
Albuquerque, New Mexico
PURSUANT TO THE APPLICABLE RULES OF CIVIL
PROCEDURE this deposition was:
BRIAN L. FERRALL
Attorney for Intel
Marcia J. Schick, CM
Hughes Southwest Court Reporters
110 2nd Street S. W. Suite 505
Albuquerque, New Mexico 87102
(Exhibit No. 7 - STC's Responses to Intel.)
So, we have marked as Exhibit 7 a document
entitled STC's Responses to Intel's Corporation Second Set
of Interrogatories, Nos. 30 to 32. Have you ever seen
this document, Dr. Hersee?
I haven't seen this document but I believe I
have seen an e-mail that contains this information.
These Interrogatories request information about
the equipment used in the development of the 998 patent
and some other patents; right? Did you provide any
information regarding that equipment?
I was asked to verify if this equipment was
accurate and to the best of my knowledge, it is.
So, your role was verifying, not actually
identifying the equipment in the first place?
Does CHTM have the capability of manufacturing a
working integrated circuit?
What are the -- to the best of your knowledge,
what are the elements that are missing?
Well, that is a big question. Okay. There is a
whole design aspect that we don't have. We do have some
advanced lithography capabilities to make small features.
We don't really have beyond that any metallization
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