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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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

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(Exhibit No. 7 - STC's Responses to Intel.)

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Q

So, we have marked as Exhibit 7 a document

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entitled STC's Responses to Intel's Corporation Second Set

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of Interrogatories, Nos. 30 to 32. Have you ever seen

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this document, Dr. Hersee?

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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

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the equipment used in the development of the 998 patent

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and some other patents; right? Did you provide any

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information regarding that equipment?

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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?

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A

Correct.

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Q

Does CHTM have the capability of manufacturing a

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working integrated circuit?

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A

No.

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Q

What are the -- to the best of your knowledge,

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what are the elements that are missing?
A

Well, that is a big question. Okay. There is a

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whole design aspect that we don't have. We do have some

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advanced lithography capabilities to make small features.

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We don't really have beyond that any metallization

Unsigned

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