As a Patent Owner in an instituted Inter Partes Reviews ("IPR"), one of the first and most critical tasks before you is deposing the Petitioner's witnesses, including its experts. But approaching an IPR deposition like a typical litigation deposition could be a big mistake. Unlike a typical litigation deposition, where one thoroughly probes a witness on all relevant issues to gain a better understanding of what the deponent knows, an IPR deposition needs to be treated more like a cross-examination at trial. This is because the IPR witness has already provided his or her testimony in the IPR through a declaration and, under normal