HILL et al. V. ANDERSON et al. V. SNITZER et al. - Page 22





                A It was the term I used. I'm not sure if it was the                                
          term he used.                                                                             
                Q Do you recall his using any other terms?                                          
                A I don't recall it at this point.                                                  
                Q So to the best of your knowledge no other terms were                              
          used by Dr. Snitzer or Dr. Prohaska at that time other than                               
          grating masks?                                                                            
                A Not to my memory. (SR 782, lines 7-20).                                           
                112. Later, in his cross-examination testimony, Dr. Rishton                         
          recalled the term phase mask being discussed with Dr. Prohaska                            
          and Dr. Snitzer. (SR 798-799, lines 24-15).                                               
                113. Dr. Rishton could not recall if he had ever met                                
          Drs. Snitzer or Prohaska in person (SR 754, lines 13-25).                                 
                114. Rishton could not recall if he had ever made a mask                            
          prior or subsequent to making one for the Snitzer inventors (SR                           
          757, lines 6-15).                                                                         
                115. Rishton could not recall whether he or Dr. Snitzer                             
          initiated the phone conversation to discuss making a mask for the                         
          Snitzer inventors (SR 771, lines B-24)                                                    
                116. Dr. Rishton also did not recall whether he made a                              
          presentation at a conference he attended just two months prior to                         
          his phone conversation with Dr. Snitzer or Dr. Prohaska (SR 776,                          
          lines 2-11).                                                                              
                117. Dr. Prohaska testified that he performed calculations                          


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