EXHIBIT 3 

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHI10 

SARA HAWES, individually, and on behalf of Case No. 1:17-cv-00754 

all others similarly situated, 

Judge Timothy S. Black 

Plaintiff 

V. 

MACY'S WEST STORES, INC.,

Defendant. 

DECLARATION OF TUSHAR GHOSH

I, Tushar Ghosh, declare and state as follows:

1. I am over the age of l8 and under no disability. I have personal knowledge of the 

matters set forth herein, unless otherwise specifically indicated.

2. My name is Tushar Ghosh. I am the William A. Klopman Distinguished Professor

of Textiles at the Wilson College of Textiles at North Carolina State University. I received my 

Ph.D. in Fiber and Polymer Science from North Carolina State University in 1987. I have been a 

member of the faculty at North Carolina State University since 1987. I have also served as a 

visiting Professor at the University of Sydney and the Indian Institute of Technology at Bombay.

3. In 2007, I received the Fiber Society's Founders Award for outstanding

contributions to the science and technology of fibrous materials. My research activities are devoted 

to the technologies of fabric formation, mechanics of fiber assemblies and their characterization,. 

and fiber-based structures for adaptive and responsive textiles.

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4. I teach classes to both graduate students and undergraduates. The classes I have 

taught recently include courses on weaving technology, functional textiles, and characterization of 

textile materials. 

5. I have been retained by counsel for AQ Textiles, LLC to provide analysis of issues 

related to thread count and composition of CVC sheets.

6. In connection with my work in this case, I generated a written report dated May 1, 

2021. A true and accurate copy of that report, including all exhibits are attached to this Declaration

as Exhibit A. 

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true 

and correct. 

Executed on May 3, 2021. 

ugho k UUn 

Tushar Ghosh, Ph.D. 

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EXHIBIT A
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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO

SARA HAWES, individually, and on behalf of 

all others similarly situated,

Plaintiff,

v.

MACY’S WEST STORES, INC.,

Defendant.

Case No. 1:17-cv-00754

Judge Timothy S. Black

EXPERT REPORT OF TUSHAR GHOSH, Ph.D.

May 1, 2021

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I. Background and Task

1. My name is Tushar K. Ghosh. I am currently the William A. Klopman 

Distinguished Professor of Textiles at the Wilson College of Textiles, North Carolina State 

University in Raleigh, NC. 

2. My educational background covers a broad area of Fiber Science & Textile 

Technology. My areas of academic interests include the formation of textile structures, mechanics 

of fiber assemblies, characterization of fibrous materials, design and development of functional 

fibers, and fiber-based structures for adaptive and responsive textiles. In recent times I have been 

engaged in research in the fabrication of sensors and actuators involving polymer nanocomposites, 

electroactive polymers, artificial muscles, and biomimetic systems. I have been teaching courses 

on Technology of Weaving, Characterization of Textiles, and Technical Textiles at both graduate 

and undergraduate levels. A copy of my curriculum vitae, including a list of my publications, is 

attached as Exhibit 1. 

3. I have not testified by deposition or at trial in the last four years.

4. I have been retained by counsel for Defendant Macy’s West Stores, Inc. (“MWSI”). 

My rate for this matter is $300 per hour and $3,000 per day if required to travel. To date, my fee 

for completing this work is approximately $ 13,000.

5. In informing my opinion, I have reviewed, among other things, the Third Amended 

Complaint, the Report of Sean Cormier, deposition transcripts, and other documents provided to 

me by counsel for MWSI. A complete list of the documents I have considered is attached as 

Exhibit 2. Additionally, I had an interview with employees1of Creative Textiles about the 

manufacturing process they use to make bedsheets sold to AQ Textiles. 

 

1 Vijay Agrawal, Saching Kulkarni, and Parag Tejani.

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6. I have also examined four sets of sheets including one set (Somerset) that I 

understand is the set Plaintiff claims to have purchased, which was provided by Mr. Cormier, and 

three sets (Optimal Performance, Fairfield Square, and Camden) of sheets provided by Macy’s 

counsel, which are the same products referenced by Mr. Cormier as ones he purchased to test. 

II. Plaintiff’s Contentions

7. After reviewing the Third Amended Complaint and Cormier Report, I believe the 

main issues of contention, in this case, are the following;

8. [Contention 1] The sheets sold by Macy’s and supplied by AQ Textiles do not 

have the thread counts represented by Macy’s on the marketing and labeling of the products and 

that the thread counts are much lower.

9. [Contention 2] The supposed alternative method used by Creative Textiles and AQ 

Textiles to count the number of threads in the bedsheet is wrong and does not follow the methods 

suggested by ASTM D3775-03 (Updated version is ASTM D3775-17).

10. [Contention 3] Lastly, the consumers buy bedsheets of higher thread count because 

they are of better quality, more durable, softer, and/or better for sleeping than those with lower 

thread count. (Or simply stated, “High thread count bed sheets are of better quality.”)

11. I plan to address each of these contentions in the following section after a brief 

review of the relevant technologies and terminologies. 

III. Basis for Opinions

12. Based on my work on this case to date, this report contains a complete statement of 

the opinions I intend to provide in this matter. If additional evidence is uncovered or if Plaintiff’s 

expert provides additional information or opinions, I will respond if asked. My opinions on these 

issues are based on my research, academic, and industrial experience over the last 45 years. Over 

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these years I have taught courses on the technology of textile manufacturing (e.g. ring spinning, 

weaving, etc.) and products as well as their characterization regularly. Before I offer my opinion 

on the allegations, I believe it is essential to understand the basic terms and technologies that are 

common to all woven textile products and the specific technology involved in the weaving of the 

subject product(s) as generally described in the US Patent 9,131,790. The structural design of 

textiles for a specific application requirement(s) is a complex process of optimization. Design, 

manufacturing technologies, as well as material properties, determine the structural and eventual 

performance of the products. In the process I also plan to define the common terminologies for 

easier understanding of the discussions that follow;

Relevant Textile Terms and Definitions 

13. Terminologies used in textiles have evolved over thousands of years sometimes 

they are regional and often contextual. In light of some of the erroneous and misleading comments 

(cf. Section V) made by the plaintiff’s expert, it is important to define the terms clearly, using 

reliable sources before launching into the discussion of the facts in this case. The definitions 

presented below are cited from two sources, the Standard Terminology Relating to Textiles (D123-

19) published by ASTM International (ASTM), and the Textile Institute’s (TI) Textile Terms and 

Definitions2. In some instances, the emphasis is added to indicate their particular relevance to this 

case.

Fiber: A generic term for any one of the various types of matter that form the basic 

elements of a textile and that is characterized by having a length at least 100 times its diameter.

[ASTM]

 

2 Textile Terms and Definitions, 8th ed. (1986), The Textile Institute, ISBN 0 900739 82 7

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A unit of matter characterized by flexibility, fineness, and a high ratio of length to 

thickness. [TI]

Monofilament: a single filament which can function as a yarn in commercial textile 

operations, that is, it must be strong and flexible enough to be knitted, woven, or braided, etc. 

[ASTM]

(TI lists monofilament as “monofilament yarn” and refers the reader to “see continuousfilament yarn”.)

Yarn: A generic term for a continuous strand of textile fibers, filaments, or material in a 

form suitable for knitting, weaving, or otherwise intertwining to form a textile fabric.[ASTM]

A product of substantial length and relatively small cross-section consisting of fibers and/or 

filament(s) with or without twist. (Note 2: Staple, continuous filament, and monofilament yarns 

are included, Note 4: Zero twist continuous filament yarns are included) [TI]

Continuous Filament Yarns: a yarn made of filaments that extend substantially 

throughout the length of the yarn. [ASTM]

A yarn composed of one or more filaments that run essentially the whole length of the yarn.

(Note: Yarns of one or more filaments are usually referred to as monofilament and multifilament, 

respectively.) [TI]

Single yarn: the simplest strand of textile material suitable for operations such as weaving, 

knitting, etc.

Plied yarn: An alternative to the term folded yarn (TI)

Folded Yarn; doubled yarn; plied yarn: A yarn in which two or more single yarns are 

twisted together in one operation, e.g., two-fold yarn, three-fold yarn, etc. [TI]

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Pick: (1) A single operation of the weft-inserting mechanism in weaving. (2) A single weft 

thread in a fabric as woven. Note: A single picking operation in weaving may insert more than 

one pick (i.e., weft thread) in the fabric. [TI]

Pick count: in woven fabrics, the number of individual filling yarns per inch of fabric 

regardless of whether they are comprised of single or piled components.

Pick, dead; crammed pick: A pick on which the take-up motion is put out of action. [TI]

Thread Count: in woven textiles as used in sheets and bedding, the sum of the number of 

warp yarns (ends) and filling yarns (picks) per unit distance as counted while the fabric is held 

under zero tension and is free of folds and wrinkles, individual warp and filling yarns are counted 

as single units regardless of whether comprised of single or plied components. [ASTM]

Denier: the unit of linear density, equal to the mass in grams of 9000 m of fiber, yarn, or 

other textile strand that is used in a direct yarn numbering system. [ASTM]

Woven Fabric and Weaving Technology: A Brief Overview

14. A woven fabric (Figure 1) is a planar structure consisting of two sets of yarns, 

warp, and weft (fill), interlaced perpendicularly to each other. Warp yarns lie along the length of 

the fabric. The single warp yarn is called an end. Filling yarns lie normal to the warp direction, 

along the width of the fabric, a single filling yarn is called a pick.

15. Weaving is a very old art that has evolved into a productive, complex, and versatile 

technology. Yet, the fundamental underlying principle of weaving has remained essentially the 

same for more than 6000 years.

3

 

3 Leslie Eadie and Tushar K. Ghosh, J. R. Soc. Interface (2011) 8, 761–775 doi:10.1098/rsif.2010.0487

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16. Weaving is a process of interlacing two sets of yarns, perpendicular to each other, 

called warp and weft (or filling), see Figure 2. The order of interlacement is determined by the 

fabric design. Before the actual weaving process, the warp yarn is prepared using multiple steps

(winding, warping, sizing, etc.). The product of the warp yarn preparation is a yarn package 

called weaver’s beam, in which thousands of yarns are 

assembled parallel to each other. In the last step of the 

warp yarn preparation, these warp yarns are 

individually drawn through various machine 

components including the heddles (often mounted on 

a harness frame) to facilitate control of these yarns 

during weaving. While each warp yarn (also called an 

end) is drawn through a hole in a heddle, these heddles are separated into groups of two or more 

and mounted on harnesses or harness frames.

17. During the weaving process, several motions or mechanisms are activated in 

sequence over one weaving cycle (discussed in more detail later) to insert one filling yarn into the 

warp. These mechanisms are shedding, filling insertion, beat-up, and fabric take-up & warp letoff. 

Figure 1: Plan view of the simple woven fabric.

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Figure 2 Schematic of a weaving machine

18. In shedding, the warp yarns are opened up in two sections to form a shed, an 

interlacing path, for the filling yarn, see Figure 2. 

19. Once a shed is formed, the filling insertion mechanism is activated to insert a filling 

yarn through the shed, see Figure 2. In this process, a discrete length of yarn is taken from an 

external filling yarn supply package and is propelled through the shed utilizing a fluid jet (air or 

water), or a projectile, or one or two rapiers (a rapier is a thin rod with a yarn clamp or gripper at 

one end). 

20. Following the filling insertion, (the shed may or may not close/change), in a beatup, the filling yarn just inserted is pushed close to the last filling yarn using a comb-like device 

called a reed. Just about the same time, the fabric take-up winds the 

length of fabric (just woven) same as the pick-spacing on the cloth

roll, and the warp let-off releases the required length of the warp. This 

completes the weaving cycle. The density of picks (proximity of the 

filling yarns) most commonly described as the number of picks per Figure 3. It takes one weaving cycle to 

insert one pick

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inch is controlled by the take-up mechanism. This sequence of events completes the weaving 

cycle. Figure 3 represents the schematic of the weaving cycle. 

21. A weaving machine of today is capable of completing 300-2000 weaving cycles 

per minute, depending on the technology and product/raw material type. The primary limitation of 

this age-old technology, based on sequential completion of events (or activation of mechanisms), 

has always been that one weaving cycle corresponds to the insertion of one pick. This severely 

limits the productivity of a weaving machine, typically measured in length of fabric produced per 

unit time (e.g. m/hour).

22. Efforts to overcome this limitation have primarily been directed toward the 

development of multiphase weaving technologies4that involve the simultaneous insertion of 

multiple picks. Theoretically, this approach should allow a multi-fold increase in productivity. 

However, commercial success has been spotty because of the complexity of the processes and 

limited design capability. The technology used to manufacture the sheets that are at issue in this 

litigation, as described in the U.S. patent 9,131,790 addresses this issue of productivity in a very 

limited manner.

5

 

4 K.L. Gandhi, The fundamentals of weaving technology, Editor(s): K.L. Gandhi, In The Textile Institute Book Series, 

Woven Textiles (Second Edition), Woodhead Publishing, 2020, Pages 167-270.

5 Agarwal, A. (2015), PROLIFERATED THREAD COUNT OF A WOVEN TEXTILE BY SIMULTANEOUS 

INSERTON WITHNA SINGLE PICK INSERTON EVENT OF A LOOMAPPARATUS MULTIPLE ADJACENT 

PARALLELYARNS DRAWN FROMA MULT-PCK YARN PACKAGE (US 9,131,790 B2), U.S. Patent and 

Trademark Office. 

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Fabric Design

23. The process of fabric design for 

a given application, in a broad sense,

involves many parameters (see Table 1). In 

the context of this lawsuit, two parameters

are relevant, namely the interlacement pattern and end/pick density. The yarn interlacement 

pattern generally refers to the up and down position of an individual warp yarn with respect to the 

filling yarns (or vice versa). This in turn is controlled by the up or down positioning of the 

harnesses to form a shed before the filling insertion. For instance, the example of interlacement 

shown in Figure 4a shows warp yarn numbers 1 and 2 are going over and under filling yarn 

number 1, respectively, and subsequently over and under alternating filling yarns. This

interlacement, called plain weave, is implemented by inserting one filling yarn or pick in a shed 

formed in one weaving cycle. In another design, called warp rib multiple picks are inserted in the 

same shed opened during three weaving cycles, see Figure 4b. It is important to note that in the 

typical weaving process every pick in this design (and others) is inserted in separate weaving 

cycles even when they are being inserted in the same shed, and thereby severely limiting the 

productivity of a weaving machine. This is what is addressed in U.S. patent 9,131,790. 

Figure 4. Three-dimensional view of two weave designs, (a) plain weave, (b) 4x4 warp rib weave

Table 1. Complexity of fabric design

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Comments on US Patent 9, 131, 790

24. U.S. patent 9,131,790, or “the ‘790 patent” describes how to simultaneously insert 

multiple adjacent parallel yarns within a single pick. The patent describes the texturing (falsetwist) and winding of “Multi-pick” filling yarn packages as part of the filling yarn preparation

as well as the use of these packages to supply filling yarns in a weaving machine. 

25. In the multi-pick filling yarn package described in the ‘790 patent, individual 

polyester yarns removed from separate yarn packages are textured and intermingled, individually,

for bulk and coherence before being assembled side by side (or in parallel) and wound on a takeup package. The winding process does not employ any assembly twist or intermingling. 

26. In the weaving process, the filling yarns coming from one or more of the multi-pick 

filling yarn packages are fed to the filling insertion mechanism of a loom to weave fabrics having

“ 90 to 235 ends per inch warp yarns and from 100-765 picks per inch multi-filament polyester 

weft yarns.”

27. Using the methods described in this patent, it is possible to insert multiple picks in 

the same shed in one weaving cycle. For example, to weave the design shown in Figure 4b, all 

of the picks inserted in the same shed can be inserted in a single weaving cycle. Therefore, the 

design described in Figure 4b can be woven at a speed four times higher than the common practice. 

28. From my conversations with employees of Creative Textiles, it is my understanding 

that the CVC sheets manufactured by Creative, imported by AQ, and sold to Macy’s (which are at 

issue in this lawsuit) were manufactured using this process. 

IV. Opinions

If called upon to testify in this matter, I would offer the following opinions in response to 

Plaintiff’s contentions identified above.

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29. [Contention 1] The sheets sold by Macy’s and supplied by AQ Textiles do not 

have the thread counts represented by Macy’s on the marketing and labeling of the products and 

that the thread counts are much lower.

After examining relevant documents (including deposition transcripts, the ‘790 patent, test 

reports, and the products analyzed by Plaintiff’s expert, Sean Cormier), I believe the thread counts 

calculated by Mr. Cormier are incorrect. While there is no debate about the number of ends in the 

products, the allegation about the thread count stems from the misinterpretation of the number of 

picks per inch of the bedsheets. 

The fabrics in question are constructed of staple fiber yarns in the warp direction and zerotwist continuous filament yarns in the filling direction. Understandably, a superficial examination 

of the fabric might produce an erroneous count of the picks per inch as reported by the plaintiff’s 

expert Mr. Cormier. The fabrics in question, however, are produced using the technology 

described in US Patent 9, 131, 790 (henceforth called multi-pick technology). For example, one 

set of specifications for the 900 TC Somerset by AQ Textiles has 185 ends/inch of 60’s cotton 

count warp yarn and 69 insertions of 10 picks/insertion (OR 690 picks/inch) of 15 denier polyester 

continuous filament yarns, each having 8 filaments. In other words, a cursory examination of the 

fabric may suggest that the fabric has 185 ends/inch and 69 pick insertions/inch.

Figure 5 Optical micrographs of fabric 900 TC Somerset by AQ Textiles, (a) montage of planar views to show 

the absence of twist in the filling yarn, (b) magnified view of part of image (a), (c) Top view of a filling yarn in 

the fabric, (d) side view of the filing yarn in image (c). In Images a and b the arrows point to the warp 

direction.

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However, a closer examination (like the one I performed) yields a significant difference between 

the fabric structures produced by a traditional one-pick/weaving cycle (or insertion) and the 

multipack technologies, and hence the real number of picks/inch. Figure 5 shows various low 

magnification optical micrographs of the same fabric. The planar view in Figure 5a shows the 

twisted staple fiber yarns of (almost) cylindrical shape in the warp direction, whereas the filling 

direction shows the ribbon-shaped bundle of polyester continuous filament yarns. This 

observation, further validated in the planar and side views of the weft yarns presented in 

Figure 5c and d, is the key to understanding the unique structure. The planar and side views 

of the filling yarns demonstrating a ribbon-like cross-section are due to the side-by-side assembly 

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of ten filling yarns of 15/8/0 (denier/no. of filaments/twist) before insertion in the same shed. This 

construction, observed in the images in Figure 5, is exactly what is described in the ‘790 patent as

the multi-pick technology. While the ribbon-like filling yarn bundle inserted together in one 

filling insertion has mostly survived the subsequent processes of dyeing and finishing, the 

boundaries of these yarns are unclear in the images because of the expected filament migration 

from one to the other in the absence of twist. On the other hand, if the filling yarns were a 10-ply 

yarn having an assembly twist, it would have appeared in a more circular cross-section shape. In 

counting the number of picks per inch, one should therefore count all of the yarns included 

in the ribbon-like bundle. Mr. Cormier failed to do so, and his thread counts are therefore 

incorrect. 

30. [Contention 2] The alleged alternative method used by the manufacturer and AQ 

Textiles to count the number of threads in the bedsheet is wrong and does not follow the methods 

suggested by the Standards, in specific ASTM D3775-03 (Updated version is ASTM D3775-17).

The many critical comments made in the Third Amended Complaint as well as by the 

plaintiff’s expert, Mr. Cormier, in his report and deposition on the methods used by AQ Textiles 

to count the number of threads in the bedsheet, is unwarranted, pointless, and without merit. The 

complaint repeatedly refers to a part of the Procedure 9.1.1 in the ASTM Standard D3775-03, “. . 

Count individual warp yarns (ends) and filling yarns (picks) as single units regardless of whether 

they are comprised of single or plied components.” Applying that language here means counting 

every individual weft yarn (pick). If Cormier’s interpretation of the ASTM D3775 procedure is 

that any number of picks inserted in one shed should be counted as only one pick, that is incorrect.

It is not the case that the multi-pick technology used in the manufacture of the products I reviewed 

inserts a plied yarn in a single insertion; that is a misunderstanding of the manufacturing method 

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and the resulting fabric structure. A plied yarn requires some level of assembly twist (refer to the 

definition earlier) and there is no twist in the ribbon-like multi-pick bundle inserted in the fabric. 

This particular procedural point does not even appear in the latest version of the ASTM standard

(D3775-17). Procedure 9.1.3 in ASTM D3775-17 clearly states, “When two yarns are laid-in 

together and parallel, count each yarn separately, as a single unit, regardless of whether it is 

comprised of single or plied components.” This part of the procedure is most pertinent to the multipick technology presented in patent ‘790 earlier. The pointed tool or needle used to separate the 

individual yarns from the parallel bundle for counting is also clearly within the scope of the 

standard method and described in the section Apparatus, “6.1 Use any suitable device, such as pick 

glass, rule and pointer, microfilm reader, or projection equipment.”

31. [Contention 3] Lastly, it is asserted that the consumers buy bedsheets of higher 

thread count because they are of better quality, more durable, softer, and/or better for sleeping than 

those with lower thread count. (Or simply stated, “High thread count bed sheets are of better 

quality.”) 

I have not conducted any consumer studies, which would be necessary to truly judge why 

any given consumer buys a bedsheet; presumably, they do so for all sorts of reasons. But in my 

opinion, this assertion is born out of a simplistic understanding of textiles and their structureperformance relationship. Higher thread count (and by implication lots of finer yarns jammed into 

a small space) does not necessarily produce bedding of “higher quality, durability, longevity, 

softer, and/or better for sleeping than lower thread count bedding.” In fact, for specified fiber 

material, a fabric made out of densely packed (more numbers per unit length) fine yarns is more 

likely to be stiff, crisp, and more paper-like. The reason is simple, the softness of a textile structure 

is derived from the ability of its constituents (yarns or fibers) to move and allow deformation. In a 

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densely packed structure that becomes more difficult. This clear difference is seen in the 

characteristics of a film and a fabric. The voids and discontinuities accommodate applied 

deformation with relatively little resistance. For the same reason, a twisted structure is generally 

stiffer than a similar untwisted structure. 

V. The Numerous Erroneous and Misleading Comments by Mr. Cormier

32. The expert opinions offered by Mr. Cormier in his report and deposition are strewn 

with inaccuracies and misstatements. It is important to point some of these out for the sake of 

proper contextualization of the facts in this case.

A. Errors Regarding Basic Textile Terms and Principles

First, Mr. Cormier makes many simple errors with respect to the terminology and 

fundamental principles involved in weaving textile products. These errors contribute to his 

incorrect conclusions regarding the products at issue.

“Polyester uses the denier system that uses the formula of 9,000 meters of yarn per one 

gram. Therefore, a size 20 Denier fiber is 1800 meters of yarn weighing one gram.” [Report, P8]

33. This explanation of denier is completely wrong. Denier is one of the units of 

fiber/yarn mass linear density. The definition is simple and it is the weight in grams of 9000 meters 

of fiber or yarn. The tortuous explanation provided by Mr. Cormier in the second sentence is also 

erroneous; 9000 meters of a 20 denier fiber should weigh 20 grams and 1800 meters of it should 

weigh 4 grams, where does one gram come from? 

“Q. So if it was a hundred grams for 9,000 yarns, that would be a hundred denier?

A. Well, I generally go back the other way. So if it's 9,000 weighing one gram, 900 would 

be a 10 denier, 90 would be a hundred denier.” [Dep, P96-97]

34. This dialogue demonstrates a deep lack of understanding of the fundamentals of 

textile terms and units of measure. Here, Mr. Cormier is given repeated opportunities to correct 

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himself. Instead of recognizing the mistakes, He responds with the line “Well, I generally go back 

the other way. So if it's 9,000 weighing one gram, 900 would be a 10 denier, 90 would be a hundred 

denier.” Once again, it’s a meaningless, confusing interpretation of a simple concept of denier. 

“The polyester fibers are very fine, and the fiber itself is not suitable for production, as it 

is too weak. The fibers are thus combined together to form a yarn, and the yarn, consisting of 

multiple fibers/strands, is now ready for use as a building block to make fabrics.”[Report, P8]

35. This is one of the simplistic and misleading comments in the report. The fineness 

of the commonly available commercial polyester fibers is in the range of 10-200 microns and their 

strength varies between 5-10 grams per denier.6 Polyester fibers are considered one of the 

strongest of the common fibers and are generally stronger than cotton, wool, silk, rayon, and nylon 

fibers [5]. Polyester monofilaments are used in making many technical textile products. The staple 

(short lengths of ~1 inch) or continuous filaments of polyester fibers are combined to form a yarn 

not just for strength but more importantly to make a continuous strand (in case of staples) as well 

as a yarn that is suitable for the intended application in terms of other properties such as bulk, 

flexibility, etc. 

“Yarns are made from fibers, and it takes as many as 10 or 12 polyester FIBERS to make the 

yarn.” [Report, P14]

36. The statement is misleading at best. According to any definition of yarn, it could 

be made of one or more fibers, depending on the need. 

“Further, in an email dated 4/27/2017, AQ states “the standard does not distinguish 

between cotton and Polyester fibers. Threads are threads and could be cotton or polyester.” But 

this is clearly not true. If one was to untwist a cotton yarn one would have thousands of individual 

cotton fibers and this simply could not be counted.” [Report, P14]

 

6 Tatsuya Hongu, Glyn O. Phillips, Machiko Takigami, Superfibers, Editor(s): Tatsuya Hongu, lyn O. Phillips, 

Machiko Takigami, In Woodhead Publishing Series in Textiles, New Millennium Fibers, Woodhead Publishing, 2005, 

Pages 65-98; Warner, S., Fiber Science, Prentice Hall (1995), ISBN 0-02-424541-0. 

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 21 of 42 PAGEID #: 2004
18 | P a g e

37. Anyone with a rudimentary knowledge of textiles would agree with the statement 

that Cormier attributed to AQ Textiles. What part of it is wrong? Cotton is available only as staple 

fibers and a staple fiber is not a yarn (or a thread) until these fibers are twisted together to form a 

continuous strand. In the absence of a twist, there is no yarn. The same would happen to a yarn 

made of any staple fibers of polyester and/or other fibers. In contrast, a continuous filament of any 

kind (polyester, nylon, silk, etc.) could form a yarn (see definitions) with or without a twist. 

Therefore in counting the number of ends or picks per inch the type of fiber is immaterial. 

“Q. Is it your testimony that those are the three types of weave in fabric and any other type 

is a subtype of one of those three?

A. Yes.” [Dep, P15]

38. Contrary to this assertion, there are almost infinite varieties of weave designs. 

“Q. Sir, are either of those definitions definitions that you're familiar with?

A. I call them -- the ravel, I would call a reed. And really the reed is where you would put 

the individual yarns through so that you can control the up and down motion. As I said, in a plain 

weave, where you could have over-under, so I call it the reed.” [Dep, P105]

39. This exchange in a way demonstrates a lack of understanding of the weaving 

technology for textile manufacturing on Mr. Cormier’s part. The reed has nothing to do with 

controlling the up and down motion of the yarns. He is confusing harnesses with the reed. 

B. Errors in Mr. Cormier’s Analysis and Conclusions

Second, Mr. Cormier makes several errors directly related to his analysis and evaluation 

of the products at issue. Those errors, along with the other issues discussed in the following, make 

his opinions deeply flawed. 

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“. . . consumers purchase the products reasonably believing that they were purchasing a 

product with the stated thread count and which is of higher quality, durability, longevity, and/or 

softness, and/or better for sleeping, than products with a lower thread count.” [Report, P4]

40. There is no rational scientific reason for this belief. In science, assertions of these 

kinds require supportive and meaningful discussion or evidence in the form of citations. In the 

absence of that, it’s simply speculation. Textiles made of higher thread count are almost certainly

thinner, less permeable, and stiffer. While subjective characteristics such as quality, durability, and 

longevity are application-specific and as such have little to do with higher thread count, attributes 

of softness and “better sleeping” are very likely to be harmed by higher thread count. For reasons 

explained earlier, a higher thread count is likely to produce relatively stiffer and crisper fabric. 

The softness of a fabric depends on many of its mechanical properties, the most important among 

them are lower stiffness in compression and bending. 

“Not one of the tools allows you to untwist the yarns and count the fibers because that is 

not the way to count yarns.”[Report, P13]

41. This comment is made while discussing the various standard test methods. What is 

the relevance of the sentence? Nowhere in the documents I reviewed, is the mention of untwisting 

or evidence of any tools used to untwist the yarns. The micrographs presented above (Figure 5) 

clearly show the absence of any twist in the filling yarns, therefore the question of untwisting is 

irrelevant.

“To this day, ASTM standard requires manufacturers to count the number of yarns and 

not the fibers. As explained above, yarns are made from fibers that have been either twisted or 

laid together and carried across the fabric via the rapier on a loom.” [Report, P13]

42. Once again, the comment is immaterial to this discussion. I have not noticed any 

evidence of counting fibers anywhere. If the fibers were counted the 900 TC Somerset would have 

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20 | P a g e

been reported to have 5,520 picks/inch (69 insertions

inch

× 10 picks

insertion

× 8

fibers

pick

). That is obviously 

not true. 

“They do not include the number of cotton fibers used. Fibers are fibers and yarns are

yarns, and if one separates the fibers one no longer has a yarn. Fibers are not counted in the 

standard, and again AQ is treating the warp different from the filling.” [Report, P15-16]

43. Once again, a very confusing and misleading statement. The warp and filling yarns 

are of different kinds in the subject product. The warp is a staple fiber yarn and the filling yarns 

are made of continuous filaments (without twist). In both cases, the yarns (see definition earlier)

are counted. There is no untwisting involved in either case. 

“Q. Tell me again why you don't think you could carry more than one across at a time.

A. Well, it's going to slow down the whole process. It's going to make the production of the 

bedsheets four, five times longer than what it normally takes.

Q. So if you're inserting -- explain to me how if you're inserting more than one weft yarn 

at the same time that would be slower than inserting them one at a time?

A. The rapier has to carry the individual yarns across. So the rapier would have to go 

across 765 times.” [Dep, P140]

44. This exchange happens during the discussion on the US patent ‘790. As explained 

earlier, the main incentive to insert multiple picks per weaving cycle (or insertion) using the multipick technology is to increase the manufacturing speed. The length of fabric produced per unit 

time can be calculated using the relationship,

(

length of fabric produced

min ) = (

rev

min

) × (

picks inserted

rev ) ×

1

picks

inch

⁄

Therefore, more “picks inserted/rev” will increase the manufacturing speed. While the 

rapier travels 765 times across the loom, it will produce a lot more length of fabric. 

“Q. So what is your basis for testifying about what this person is trying to do?

A. Well, it's the –

MR. LEGANDO: Object to form.

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 24 of 42 PAGEID #: 2007
21 | P a g e

A. It's the whole point that I brought up. These guys are not counting yarns. They are

counting fibers. You're not allowed to count the fibers. Why are they treating the weft yarns

differently than the warp yarns? My report shows, you have fiber industry. You have a yarn 

industry. You have a fabric industry. Okay. And what we're talking about is counting the yarns, 

not counting the fibers.” [Dep, P 177]

45. Once again, this exchange is not pertinent to any of the documents I have reviewed. 

Nowhere have I seen evidence of anyone counting fibers. As I pointed out earlier, counting fibers 

would result in a very large number of threads per inch, well in excess of the represented thread 

counts. 

“Q. Why did customers think that higher thread count is higher quality?

A. As I said, let's take the -- an example of durability. That would be an example of quality.

So, you know, if you take one stick, you're out in the woods, you're a kid. You take one stick, 

you break. It's easy to break. You go and you break a bunch of sticks, it's much harder to break. 

So it's more durable. So the more sticks or the more yarns that you would have the more durable 

the product would be.” [Dep. P256]”

46. This is one of the examples of many simplistic and misleading comments made 

during the deposition. The durability of a bed sheet is not a function of strength alone. What kind 

of strength (tear, tensile, etc.) is he talking about? And the strength of a fabric is not dependent on 

the thread count alone. If strength is paramount, bedsheets will be made of glass or Kevlar fibers. 

The analogy of sticks is misleading is best. What about the strength, dimension, etc. of individual 

sticks? The design of textiles is complex and it begins with the understanding of the end-use 

requirements and analysis of the complex interaction of material and structural characteristics. The 

durability of a bedsheet should depend to a large extent on its ability to survive laundering, 

abrasion, etc. 

VI. Conclusion

47. Based on my review of the materials I have been provided to date, I believe that the 

contentions in this lawsuit lie in the misunderstanding of fundamental textile technologies and the 

specific technology used to manufacture the bedsheets. These misunderstandings are reflected in 

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 25 of 42 PAGEID #: 2008
Cormier's report. In my opinion, based on the weaving methods used by the manufacturer and 

described in the '790 patent, the appropriate way to measure the thread counts is to count each of 

the picks inserted into each shed, which Cormier did not do. In my opinion, the thread count on 

the packaging for the 900 TC Somerset sheets is correct. Also, while I am not aware of any 

consumer studies to determine what factors might lead a consumer to consider a bedsheet to be 

superior in quality, it is my opinion that a higher thread count does not necessarily mean a higher

quality ofa bedsheet. 

Dated: May 1, 2021 

nstor k. Ghsh 

Tushar Ghosh, Ph.D. 

22 |P agc 

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 26 of 42 PAGEID #: 2009
EXHIBIT 1

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 27 of 42 PAGEID #: 2010
Tushar K. Ghosh

Professor, College of Textiles, North Carolina State University

EDUCATION

North Carolina State University, Raleigh, NC. 

Ph. D., Fiber and Polymer Science (July 1987)

North Carolina State University, Raleigh, NC. 

M. S., Textile Materials and Mgmt., Minor: Mathematics (Dec. 1984)

Indian Institute of Technology, New Delhi, India. 

M. Tech., Textile Engineering. (July 1978)

University of Calcutta, Calcutta, India 

B. Sc. Tech., Textile Technology, (Aug. 1975) 

PROFESSIONAL EXPERIENCE

North Carolina State University, Raleigh, NC.

William A. Klopman Distinguished Professor (2018-present), College of Textiles, NC State University

Professor (2008-2018) Textile Engineering, Chemistry, and Science Dept.

Program Director (2008-2012), Textile Technology program 

Professor (1999-2008) Textile & Apparel, Technology & Mgmt. 

Assoc. Professor (1993-1999) Textile & Apparel, Technology & Mgmt.

Assistant Professor (1992-1993) Textile & Apparel Mgmt.

Visiting Assistant Professor (1987-1992) Textile Eng. & Science 

Research Assistant, (1982-1987) Textile Eng. & Science, Teaching Assistant, Mathematics

National Institute of Natural Fiber Engineering & Technology, Calcutta, India. 

Scientist (1978-1981) Textile Technology Dept.

Bombay Dyeing & Manufacturing Co. Ltd., Bombay, India 

Departmental Assistant (1975-1976) Sulzer Weaving Machinery Dept.

PROFESSIONAL AFFILIATIONS

American Association for the Advancement of Science (AAAS, 2015-present)

IEEE (2018-present)

Fiber Society (1983 – present)

National Parachute Technology Council (1996-1999)

Industrial Fabrics Association International (2001-2008)

SPIE (2001-present)

RESEARCH OVERVIEW

My research interests, while very diverse, maintain a central focus on design, processing, characterization, and 

application of textile materials and technologies for functional applications. Early in my academic career, I 

have worked exclusively on the processing, and characterization of textile structures. More recently, most of 

the research problems I have addressed, alone or in collaboration, have focused on the functional 

enhancement of textiles at all hierarchical levels by manipulating their fundamental composition and 

structure. In a pioneering work, we have utilized the concept of bicomponent fibers with dielectric elastomers

to develop muscle-like actuating fibers. Other recent works have focused on (i) development of electroactive 

thermoplastic elastomer gels with tunable electromechanical properties, (ii) elastomeric nanocomposite as a 

printed sensory layer on fabrics for strain monitoring, (iii) fiber-based multi-modal sensors for biomedical

applications, including prosthetic socket inner-environment monitoring, and (vi) improving the performance 

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 28 of 42 PAGEID #: 2011
TUSHAR K. GHOSH

(Page 2 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

of rubber synchronous belts. While much of my current research involves responsive polymers, fiber-based 

sensors and actuators, and nanocomposites, we have recently begun exploring biomimetic soft-robotics 

systems using carbon nanotube fiber-polymer composites. 

INSTRUCTIONAL EXPERIENCE

I have taught a wide range of courses primarily on textile technologies at the graduate and undergraduate 

levels including Mechanics of Fibrous Assemblies, Design and Analysis of Technical Textiles, Performance 

Evaluation of Textiles, Woven Fabrics & Technology. I am genuinely passionate about teaching and I believe 

that teaching is a great privilege and an incredibly rewarding responsibility. 

AWARDS & HONORS

Illustration featured on the cover of the Advanced Functional Materials (2018)

Board of Governors Award for Excellence in Teaching, 2012-13, Nominee, College of Textiles

Illustration featured on the cover of the Journal of Polymer Science |Part B, Polymer Physics (2011)

Invited Lecturer to Summer School, Donghua University, 2012-2018

Editorial Board, Journal of the Textile Institute (2001-present)

Editorial Board, Textile Research Journal (2005-2016)

Editorial Board, Journal of Fiber Bioengineering and Informatics (2008-2016)

Pride of the Dept. Award, Textile Tech. Dept., Indian Institute of Technology, Delhi, India, 2009

Illustration featured on the cover of the Advanced Materials (2007)

Founders Award, Fiber Society, 2007

National Textile Center, Circle of Excellence, 2005

College of Textiles Outstanding Teaching Award; inducted into the NCSU Academy of Outstanding 

 Teachers (1995-96)

Visiting Scholar, School of Mathematics and Statistics, University of Sydney, 1993

SCHOLARLY PEER REVIEW ACTIVITIES

Reviewed research proposals for: The National Science Foundation (NSF)-USA, Research Grants Council (RGC) 

of Hong Kong, National Research Foundation of Korea, KAIST, American Association for the Advancement of 

Science (AAAS), and others.

Ad hoc reviewer for: Nature, Science, Advanced Materials, Advanced Functional Materials, Sensors and 

Actuators A & B, Carbon, Small, Textile Research Journal, Journal of the Textile Institute, and others.

STUDENT AWARDS & HONORS

Talha Agcayazi: Placed second in the poster session FLEX conference (2018)

A. Kapoor: Poster Award, Textiles Res. Day, College of Textiles, NCSU Most Innovative Research Poster (2017)

A. Krishnan: Poster award winner. Materials Res. Society National Meeting, Boston, MA, November (2010)

A. Krishnan: 1

st place, 5th annual NCSU Graduate Student Research Symposium (2010)

P. Vargantwar: 3rd Place (tied), Chemical & Biomolecular Engineering Schoenborn Poster Competition (2010)

Ravi Shankar: Finalist and silver medalist, MRS Graduate Student Award, 20007 

Ravi Shankar: 1

st Place, Richard D. Gilbert Award in Polymer Science (2007)

X. Y. Sun, R. Shankar: Best Overall Prize, Poster Competition, 15th Annual National Textiles Center Forum (2007)

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 29 of 42 PAGEID #: 2012
TUSHAR K. GHOSH

(Page 3 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

RESEARCH COLLABORATORS AND CO-EDITORS

 NC State University: Prof. Behnam Pourdeyhimi, College of Textiles, Prof. John Muth, Professor, 

Department of Electrical and Computer Engineering, Prof. Eddie Grant, Department of Electrical and 

Computer Engineering, Prof. Richard Spontak, Department of Chemical and Biomolecular Engineering,

Prof. Paul Franzon, Electrical & Computer Engineering, Prof. Alper Bozkurt, Department of Electrical and 

Computer Engineering, Prof. He (Helen) Huang, Department of Biomedical Engineering, Prof. Zhen Gu, 

Department of Biomedical Engineering, Prof. Brendan T. O’Conner, Mechanical and Aerospace 

Engineering, Prof. Jun Liu, Mechanical and Aerospace Engineering

 Boston University, Prof. David Holmes, Mechanical Engineering Dept., 

 Tampere University of Technology, Finland: Prof. Heikki Mattila, Professor, Textile and clothing 

production technology, 

 University of Sydney, Australia: Prof. Barrie Fraser, Emeritus Professor, Department of Applied 

Mathematics.

 Max-Planck Institute, Potsdam, Germany : Dr. Hans Börner, , Group Leader, Colloids & Surfaces,

 Indian Institute of Technology, Delhi, India: Prof. Anuj Dhawan, Assistant Professor, Department of 

Electrical Engineering.

SCHOLARLY CONTRIBUTIONS

Peer-Reviewed Publications

1. Tabor, J., Agcayazi, T., Fleming, A., Thompson, B., Kapoor, A., Liu, M., ... Ghosh, T. K. (2021). Textile-Based 

Pressure Sensors for Monitoring Prosthetic-Socket Interfaces. IEEE Sensors Journal, 21(7), 9413–9422. 

https://doi.org/10.1109/JSEN.2021.3053434

2. Tabor, J., Chatterjee, K., & Ghosh, T. K. (2020). Smart Textile‐Based Personal Thermal Comfort Systems: 

Current Status and Potential Solutions. Advanced Materials Technologies, 3, 1901155. 

https://doi.org/10.1002/admt.201901155

3. Chatterjee, K., Negi, A., Kim, K., Liu, J., & Ghosh, T. K. (2020). In-Plane Thermoelectric Properties of Flexible 

and Room-Temperature-Doped Carbon Nanotube Films. ACS Applied Energy Materials, 7. 

https://doi.org/10.1021/acsaem.0c00995

4. Agcayazi, T., Tabor, J., McKnight, M., Martin, I., Ghosh, T. K., & Bozkurt, A. (2020). Fully‐Textile Seam‐Line 

Sensors for Facile Textile Integration and Tunable Multi‐Modal Sensing of Pressure, Humidity, and Wetness. 

Advanced Materials Technologies, 6, 2000155. 

5. Chatterjee, K., & Ghosh, T. K. 3D Printing of Textiles: Potential Roadmap to Printing with Fibers. Advanced 

Materials 32 (2020).

6. Armstrong,D. P., Chatterjee, K., Ghosh, T. K., & Spontak, R.J., Form-stable phase-change elastomer gels 

derived from thermoplastic elastomer copolyesters swollen with fatty acids, Thermochimica Acta 686 

(2020) 178566

7. Wei, S., Shao, H., & Ghosh, T. K. (2019). Bioinspired Bistable Soft Actuators. ELECTROACTIVE POLYMER 

ACTUATORS AND DEVICES (EAPAD) XXI. https://doi.org/10.1117/12.2522123

8. Chatterjee, K., Tabor, J., & Ghosh, T. K. (2019). [Review of Electrically Conductive Coatings for Fiber-Based 

E-Textiles]. FIBERS, 7(6). https://doi.org/10.3390/fib706005

9. White R, McKnight M, Agcayazi T, Tabor J, Ghosh T, Bozkurt A. (2018). A Wetness Detection Technique 

Towards Scalable, Array-Based, Fully-Textile Sensing. 2018 IEEE Biomedical Circuits and Systems (BioCAS), 

1-4, DOI. 10.1109/BIOCAS.2018.8584799.

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 30 of 42 PAGEID #: 2013
TUSHAR K. GHOSH

(Page 4 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

10. McKnight M, Tabor J, Agcayazi T, Fleming A, Ghosh T, Huang H, Bozkurt A., Fully-textile Insole Seam-line for 

Multi-modal Sensor Mapping. IEEE Sensors Journal.

11. Kapoor, A., McKnight, M., Chatterjee, K., Agcayazi, T., Kausche, H., Bozkurt, A., & Ghosh, T. K. Toward Fully 

Manufacturable, Fiber Assembly–Based Concurrent Multimodal and Multifunctional Sensors for e‐Textiles.

Advanced Materials Technologies, 1800281(2018).

12. Shao, H., Wei, S., Jiang, X., Holmes, D. P. & Ghosh, T. K. Bistable Polymer Actuators: Bioinspired Electrically 

Activated Soft Bistable Actuators (Adv. Funct. Mater. 35/2018). Advanced Functional Materials 28 (2018).

13. Jiang, X., Pezzulla, M., Shao, H., Ghosh, T. K. & Holmes, D. P. Snapping of bistable, prestressed cylindrical 

shells. EPL (Europhysics Letters) 122, 64003 (2018).

14. Agcayazi, T., Chatterjee, K., Bozkurt, A. & Ghosh, T. K. Flexible Interconnects for Electronic 

Textiles. Advanced Materials Technologies, 1700277 (2018).

15. Subramani, K. B., Spontak, R. J. & Ghosh, T. K. Influence of fiber characteristics on directed electroactuation 

of anisotropic dielectric electroactive polymers with tunability. Composites Science and Technology 154, 

187-193 (2018).

16. West, A., Istook, C., Porterfield, A., & Ghosh, T. (2017). A Service Learning Collaborative to Build a 

Sustainable Enterprise for Underprivileged Women (SEuW). Journal of Textile Design Research and Practice, 

5(1), 3–16. https://doi.org/10.1080/20511787.2017.1362144

17. Agcayazi, T., Yokus, M. A., Gordon, M., Ghosh, T. & Bozkurt, A. A stitched textile-based capacitive respiration 

sensor (2017 IEEE Sensors, IEEE, Glasgow, UK, Oct 2017).

18. Agcayazi, T. McKnight M, Sotory P, Huang H, Ghosh T, Bozkurt A. A scalable shear and normal force sensor 

for prosthetic sensing (2017 IEEE Sensors, IEEE, Glasgow, UK, Oct 2017).

19. Fang, X. et al. Enhanced anisotropic response of dielectric elastomer actuators with microcombed and 

etched carbon nanotube sheet electrodes. Carbon 120, 366-373 (2017).

20. Agcayazi, T., McKnight, M., Kausche, H., Ghosh, T. & Bozkurt, A. A finger touch force detection method for 

textile based capacitive tactile sensor arrays (2016 IEEE Sensors, IEEE, Orlando, FL, USA, Oct 2016).

21. Kapoor, A., McKnight M., Chatterjee K., Agcayazi T., Kausche H., Ghosh T., Bozkurt A. Soft, flexible 3D printed 

fibers for capacitive tactile sensing (2016 IEEE Sensors, IEEE, Orlando, FL, USA, Oct 2016).

22. McKnight, M., Agcayazi, T., Kausche, H., Ghosh, T. & Bozkurt, A. Sensing textile seam-line for wearable 

multimodal physiological monitoring (2016 38th Annual International Conference of the IEEE Engineering 

in Medicine and Biology Society (EMBC) Ser. 2016, IEEE, Orlando, FL, USA, Aug 2016).

23. Di, J. et al. Stretch-Triggered Drug Delivery from Wearable Elastomer Films Containing Therapeutic 

Depots. ACS nano 9, 9407-9415 (2015).

24. McKnight M, Lin F, Kausche H, Ghosh T, Bozkurt A. (2015) Towards Paper Based Diaper Sensors. IEEE 

Biomedical Circuits and Systems Conference, Atlanta, GA.

25. Cakmak, E., Fang, X., Yildiz, O., Bradford, P. D. & Ghosh, T. K. Carbon nanotube sheet electrodes for 

anisotropic actuation of dielectric elastomers. Carbon 89, 113-120 (2015).

26. Tushar Ghosh. Stretch, wrap, and relax to smartness. Science 349, 382-383 (2015).

27. Lin F., McKnight M, Dieffenderfer J, Ghosh T, Bozkurt A. Microfabricated impedance sensors for concurrent 

tactile, biopotential, and wetness detection (2014 IEEE Sensors, IEEE, Valencia, Spain, Nov 2014).

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 31 of 42 PAGEID #: 2014
TUSHAR K. GHOSH

(Page 5 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

28. Subramani, K. B., Cakmak, E., Spontak, R. J. & Ghosh, T. K. Enhanced Electroactive Response of 

Unidirectional Elastomeric Composites with High‐Dielectric‐Constant Fibers. Advanced Materials 26, 2949-

2953 (2014).

29. Toprakci, H. A. K., Kalanadhabhatla, S. K., Spontak, R. J. & Ghosh, T. K. Polymer Nanocomposites Containing 

Carbon Nanofibers as Soft Printable Sensors Exhibiting Strain‐Reversible Piezoresistivity. Advanced 

Functional Materials 23, 5536-5542 (2013).

30. Chakraborti, P. et al. A compact dielectric elastomer tubular actuator for refreshable Braille 

displays. Sensors & Actuators: A. Physical 179, 151-157 (2012).

31. Vargantwar, P. H., Özçam, A. E., Ghosh, T. K. & Spontak, R. J. Prestrain-Free Dielectric Elastomers Based on 

Acrylic Thermoplastic Elastomer Gels: A Morphological and (Electro)Mechanical Property Study. Advanced 

Functional Materials22, 2100-2113 (2012).

32. Vargantwar, P. H., Roskov, K. E., Ghosh, T. K. & Spontak, R. J. Enhanced biomimetic performance of ionic 

polymer-metal composite actuators prepared with nanostructured block ionomers. Macromolecular rapid 

communications 33, 61-68 (2012).

33. Brelander, S., Ghosh, T., Spontak, R., Krishnan, A. & Vargantwar, P. (Electro)mechanical behavior of 

selectively solvated diblock/triblock copolymer blends. Applied Physics Letters 99, 3 (2011).

34. Krishnan, A. S., Vargantwar, P. H., Ghosh, T. K. & Spontak, R. J. Electroactuation of solvated triblock 

copolymer dielectric elastomers: Decoupling the roles of mechanical prestrain and specimen 

thickness. Journal of Polymer Science Part B: Polymer Physics 49, 1569-1582 (2011).

35. Eadie, L. & Ghosh, T. K. Biomimicry in textiles: past, present and potential. An overview. Journal of the Royal 

Society, Interface 8, 761-775 (2011).

36. Vargantwar, P. H., Shankar, R., Krishnan, A. S., Ghosh, T. K. & Spontak, R. J. Exceptional versatility of solvated 

block copolymer/ionomer networks as electroactive polymers. Soft Matter 7, 1651 (2011).

37. Shankar, R., Ghosh, T. K. & Spontak, R. J. Mechanical and actuation behavior of electroactive 

nanostructured polymers. Sensors & Actuators: A. Physical 151, 46-52 (2009).

38. Shankar, R., Krishnan, A. K., Ghosh, T. K. & Spontak, R. J. Triblock Copolymer Organogels as HighPerformance Dielectric Elastomers. Macromolecules 41, 6100-6109 (2008).

39. Shankar, R., Ghosh, T. K. & Spontak, R. J. Electroactive Nanostructured Polymers as Tunable 

Actuators. Advanced Materials 19, 2218-2223 (2007).

40. Shankar, R., Ghosh, T. K. & Spontak, R. J. Dielectric elastomers as next-generation polymeric actuators. Soft 

Matter 3, 1116-1129 (2007).

41. Shankar, R., Ghosh, T. K. & Spontak, R. J. Electromechanical Response of Nanostructured Polymer Systems 

with no Mechanical Pre-Strain. Macromolecular Rapid Communications 28, 1142-1147 (2007).

42. Hwang, J., Muth, J. & Ghosh, T. Electrical and mechanical properties of carbon‐black‐filled, electrospun 

nanocomposite fiber webs. Journal of Applied Polymer Science 104, 2410-2417 (2007).

43. Sun, X. -., Shankar, R., Börner, H. G., Ghosh, T. K. & Spontak, R. J. Field-Driven Biofunctionalization of 

Polymer Fiber Surfaces during Electrospinning. Advanced Materials 19, 87-91 (2007).

44. Arora, S., Ghosh, T. & Muth, J. Dielectric elastomer based prototype fiber actuators. Sensors & Actuators: 

A. Physical136, 321-328 (2007).

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 32 of 42 PAGEID #: 2015
TUSHAR K. GHOSH

(Page 6 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

45. Dhawan, A., Muth, J., Kekas, D., & Ghosh, T. (2006). Optical nano-textile sensors based on the incorporation 

of semiconducting and metallic nanoparticles into optical fibers. MRS Proceedings, 920, 0920-S05-06. 

doi:10.1557/PROC-0920-S05-06

46. Phillips, K. J., Ghosh, T. K. & Dickey, D. A. Stress Relaxation of Tufted Carpets and Carpet Components: 

Analysis of the Tufted Carpet Structure. Textile Research Journal 75, 485-491 (2005).

47. Dhawan, A., Ghosh, T. K., Seyam, A. M. & Muth, J. F. Woven Fabric-Based Electrical Circuits: Part II: Yarn 

and Fabric Structures to reduce crosstalk noise in woven fabric-based circuits. Textile Research Journal 74, 

955-960 (2004).

48. Dhawan, A., Seyam, A. M., Ghosh, T. K. & Muth, J. F. Woven Fabric-Based Electrical Circuits: Part I: 

Evaluating Interconnect Methods. Textile Research Journal 74, 913-919 (2004).

49. Grant, E. et al. Developing portable acoustic arrays on a large-scale e-textile substrate. International Journal 

of Clothing Science and Technology 16, 73-83 (2004).

50. Dhawan, A., Ghosh, T. K. & Seyam, A., Fiber-based Electrical and Optical Devices and Devices and Systems., 

Textile Progress 36, 1-84 (2004).

51. Velu, Y. K., Ghosh, T. K. & Seyam, A. M. Meltblown Structures Formed by Robotic and Meltblowing 

Integrated System: Interaction between Fiber Diameter, Orientation Distribution, and Pore Diameter of 

Simulated Network and Real Webs. International Nonwovens Journal 13, 8-14 (2004).

52. Ghosh, T. K. & Zhou, N. Characterization of fabric bending behavior: A review of measurement 

principles. Indian Journal of Fiber and Textile Research 28, 471-476 (2003).

53. Velu, Y. K., Ghosh, T. K. & Seyam, A. M. Meltblown Structures Formed by a Robotic and Meltblowing 

Integrated System: Impact of Process Parameters on Pore Size. Textile Research Journal 73, 971-979 (2003).

54. Farer, R., Ghosh, T. K., Seyam, A. M., Grant, E. & Batra, S. K. Study of Meltblown Structures Formed by 

Robotic and Meltblowing Integrated System: Impact of Process Parameters on Fiber 

Orientation. International Nonwovens Journal 11, 14-21 (2003).

55. Farer, R. et al. Forming Shaped/Molded Structures by Integrating Meltblowing and Robotic 

Technologies. Textile Research Journal 73, 15-21 (2003).

56. Farer, R., Batra, S. K., Ghosh, T. K., Grant, E. & Seyam, A. M. Study of Meltblown Structures Formed by 

Robotic and Meltblowing Integrated System: Impact of Process Parameters on Fiber Diameter 

Distributions. International Nonwovens Journal 12, 36-42 (2003).

57. Farer, R., Seyam, A. M., Ghosh, T. K., Grant, E. & Batra, S. K. Meltblown Structures Formed by a Robotic and 

Meltblowing Integrated System: Impact of Process Parameters on Fiber Orientation and Diameter 

Distribution. Textile Research Journal72, 1033-1040 (2002).

58. Huang, W. & Ghosh, T. K. Online Characterization of Fabric Compressional Behavior. Textile Research 

Journal 72, 103-112 (2002).

59. Ma, X., Ghosh, T. K. & Batra, S. K. Dynamic Analysis of Yarn Unwinding from Cylindrical Packages. Part II: 

The Three-Region Analysis. Textile Research Journal 71, 855-861 (2001).

60. Ghosh, T. K., Batra, S. K. & Murthy, A. S. Dynamic Analysis of Yarn Unwinding from Cylindrical Packages.

Part I: Parametric Studies of the Two-Region Problem. Textile Research Journal 71, 771-778 (2001).

61. Velu, Y., Farer, R., Ghosh, T. & Seyam, A. Formation of Shaped/Molded Meltblowing Nonwoven 

Structures. Journal of Textile and Apparel, Technology and Management 1, 1-13 (2000).

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TUSHAR K. GHOSH

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College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

62. Ghosh, T. K. in Weaving Technology for the New Millennium 37 (The Sterling Publishing Group PLC, London, 

England, 2000).

63. Batra, S., Ghosh, T. & Zeng, Q. Dynamic analysis of ring spinning: A brief review. 7, 57-64 (2000).

64. Park, T. Y., Kim, J. Y., Kim, S. H. & Ghosh, T. K. A Comparison of Tensile and Puncture Properties of Nonwoven 

Fabrics. Journal of the Korean Fiber Society 37, 103-110 (2000).

65. Ghosh, T. Development and Evaluation of a Biaxial Tensile Tester for Fabrics. Journal of Testing 

Evaluation 27, 282-289 (1999).

66. Park, T. Y. & Ghosh, T. K. Modeling and Structural Analysis of the Bending Rigidity of Nonwoven 

Fabrics. Journal of the Korean Fiber Society 36, 455-462 (1999).

67. Zhou, N. & Ghosh, T. K. On-Line Measurement of Fabric Bending Behavior—Part III: Dynamic Considerations 

and Experimental Implementation. Textile Research Journal 69, 176-184 (1999).

68. Zhou, N. & Ghosh, T. K. On-Line Measurement of Fabric Bending Behavior, Part II: The Effects of Fabric 

Nonlinear Bending Behavior. Textile Research Journal 68, 533-542 (1998).

69. Zhou, N. & Ghosh, T. K. On-line measurement of fabric-bending behavior: background, need and potential 

solutions. International Journal of Clothing Science and Technology 10, 143-156 (1998).

70. Ghosh, T. K. Puncture resistance of pre-strained geotextiles and its relation to uniaxial tensile strain at 

failure. Geotextiles and Geomembranes 16, 293-302 (1998).

71. Zhou, N. & Ghosh, T. K. On-Line Measurement of Fabric Bending Behavior, Part I: Theoretical Study of Static 

Fabric Loops. Textile Research Journal 67, 712-719 (1997).

72. Fraser, W. B., Clark, J. D., Ghosh, T. K. & Zeng, Q. The Effect of Control Rings and Cylinders on the Stability 

of the Ring-Spinning Balloon. Proceedings of the Royal Society A 452, 47-62 (1996).

73. Ghosh, T. K. & Peng, H. Analysis of Fabric Deformation in a Roll-Making Operation, Part IV, Effects of 

Variable Winding Tension. Textile Research Journal 65, 739-747 (1995).

74. Batra, S. K., Ghosh, T. K., Zeng, Q., Robert, K. Q. & Fraser, W. B. An Integrated Approach to Dynamic Analysis 

of the Ring Spinning Process, Part IV: Inherent Instability of the Free Balloon. Textile Research Journal 65, 

417-423 (1995).

75. Jain, A., Seyam, A., Ghosh, T. & Carrere, C. Application of FAST system in nonwovens, part II: Developing 

tailorability control charts for nonwoven medical apparel applications. International Nonwovens Journal 7, 

39-48 (1995).

76. Jain, A., Seyam, A. & Ghosh, T. Application of FAST system in nonwovens, part I: Objective evaluation of 

fabric performance. International Nonwovens Journal 5, 31-38 (1995).

77. Dastoor, P. H., Ghosh, T. K., Batra, S. K. & Hersh, S. P. Computer-assisted Structural Design of Industrial 

Woven Fabrics Part III: Modelling of Fabric Uniaxial/Biaxial Load-Deformation. Journal of the Textile 

Institute 85, 135-157 (1994).

78. Ghosh, T. K., Peng, H. & Banks-Lee, P. Analysis of Fabric Deformation in a Roll-Making Operation Part III: 

Effect of Viscoelasticity. Textile Research Journal 62, 669-676 (1992).

79. Ghosh, T. K., Batra, S. K., Zeidman, M. I. & Dua, B. An Integrated Approach to Dynamic Analysis of the Ring 

Spinning Process. Part III: The Effects of Coefficients of Friction and the Balloon Control Rings. Textile Praxis 

International 47, XIV (1992).

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TUSHAR K. GHOSH

(Page 8 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

80. W. B. Fraser, T. K. Ghosh & S. K. Batra. On Unwinding Yarn from a Cylindrical Package. Proceedings of the 

Royal Society of London. Series A: Mathematical and Physical Sciences 436, 479-498 (1992).

81. Ghosh, T. K., Peng, H., Banks-Lee, P., Hamouda, H. & Shin, D. H. Analysis of Fabric Deformation in a RollMaking Operation, Part II: A Dynamic Case. Textile Research Journal 61, 185-192 (1991).

82. Ghosh, T. K., Peng, H., Banks-Lee, P., Hamouda, H. & Shin, D. H. Analysis of Fabric Deformation in a RollMaking Operation, Part I: A Static Case. Textile Research Journal 61, 153-161 (1991).

83. Clapp, T. G., Peng, H., Ghosh, T. K. & Eischen, J. W. Indirect Measurement of the Moment-Curvature 

Relationship for Fabrics. Textile Research Journal 60, 525-533 (1990).

84. Ghosh, T. K., Batra, S. K. & Barker, R. L. The Bending Behaviour of Plain-woven Fabrics Part III: The Case of 

Bilinear Thread-bending Behaviour and the Effect of Fabric Set. Journal of the Textile Institute 81, 272-287 

(1990).

85. Ghosh, T. K., Batra, S. K. & Barker, R. L. Bending Behavior of Plain Woven Fabrics, Part II: The Case of Linear 

Yarn Bending Behavior. Journal of the Textile Institute 81, 255-271 (1990).

86. Ghosh, T. K., Batra, S. K. & Barker, R. L. On the Bending Behavior of Plain Woven Fabrics, Part I: A Critical 

Review. Journal of the Textile Institute 81, 245-254 (1990).

87. Batra, S. K., Ghosh, T. K. & Zeidman, M. I. An Integrated Approach to Dynamic Analysis of the Ring Spinning 

Process. Part II: With Air Drag. Textile Research Journal 59, 416-424 (1989).

88. Batra, S. K., Ghosh, T. K. & Zeidman, M. I. An Integrated Approach to Dynamic Analysis of the Ring Spinning 

Process. Part I: Without Air Drag and Coriolis Acceleration. Textile Research Journal 59, 309-317 (1989).

89. Barker, R. & Ghosh, T. K. Thermal protective performance of PBI and aramid fabrics: Measuring the effect 

of mechanical stress. Journal of Industrial Fabrics 4 (1986).

90. Gupta, P. S., Gupta, N. P., Ghosh, T. K., Bhattacharya, G. K. & De, S. K. A Novel Method of Spinning Jute 

Yarns for Decoratives. Textile Research Journal 52, 418-419 (1982).

Reviewed Monographs and Invited Works (including book chapters)

1. Tabor, J. & Ghosh, T. in High Performance Technical Textiles (ed Paul, R.) (John Wiley & Sons, Limited), 2019, 

Chicester, United Kingdom.

2. Fang, X., Chatterjee, K., Kapoor, A. & Ghosh, T. in Fibers and Textiles as Advanced Materials (ed Hu, J.) 

(Wiley-VCH Verlag GmbH, Weinheim, Germany, 2018).

3. McKnight, M., Agcayazi, T., Ghosh, T. & Bozkurt, A. Fiber-Based Sensors: Enabling Next-Generation 

Ubiquitous Textile Systems in Wearable Technology in Medicine and Health Care (ed Tong, R.) (Academic 

Press, United States, 2018).

4. Topracki, H. A. K. & Ghosh, T. K. in Handbook of Smart Textiles (ed Tao, X.) (Springer Singapore, Singapore, 

2015).

5. Ghosh, T. K., A, D. & Muth, J. F. in Intelligent textiles and clothing (ed Mattila, H.) 239-282 (Woodhead 

Publishing Limited, Abington Hall, Abington, Cambridge, UK, 2010).

6. Ghosh, T. & Chhaparwal, S. in Handbook of Nanoscience, Engineering, and Technology (eds Goddard-III, W. 

A., Brenner, D. W., Lyshveski, S. E. & Iafrate, G. J.) 21.43 (CRC Press, Taylor & Francis Group, Boca Raton, FL, 

2007).

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TUSHAR K. GHOSH

(Page 9 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

7. Ghosh, T. & Dhawan, A. in Indian Journal of Fiber & Textile Research: Special Issue on Emerging Trends in 

Polymers and Textiles (eds Chattopadhyay, R. & Jassal, M.) 170-176 (National Institute of Science and 

Communication Information Resources, CSIR, New Delhi, India, 2006).

8. Dhawan, A., Ghosh, T. K. & Seyam, A. Fiber-Based Electrical and Optical Devices and Systems. Textile 

Progress 36, 1-84 (2004).

9. Phillips, K. J. & Ghosh, T. K. The Technology of Polypropylene Tape Yarns: Processing and 

Applications. Textile Progress 33, 1-53 (2003).

10. Le Pechoux, B. & Ghosh, T. K. in Textile Progress Vol 32, No. 1 (ed Bookset, A.) 1-60 (The Textile Institute, 

Manchester, England, 2002).

11. Ghosh, T. K. in Textile Technology for China (ed Invited Paper) (The Sterling Publishing Group PLC, London, 

England, 2000).

Conference Proceedings

1. McKnight, M., Agcayazi, T., Ghosh, T. K. & Bozkurt, A. Modeling and Characterization of Multi-modal 

Sensing Fibers (Flexible Electronics Conference and Exhibition - 2018FLEX, Flex 2018, Monterey, CA, 

February 2018).

2. Spontak, R. J., Subramani, K. B., Armstrong, D. P., Cakmak, E. & Ghosh, T. K. Fabrication strategies for 

exploring the anisotropic electroactuation of dielectric elastomers (Conference Presentation) (SPIE Smart 

Structures + Nondestructive Evaluation Ser. 9798, SPIE, Las Vegas, USA, Apr 15, 2016).

3. Vargantwar, P., Ghosh, T. K. & Spontak, R. J. Ionic actuators derived from selectively solvated block 

copolymers (SPIE Smart Structures + Nondestructive Evaluation, SPIE, San Diego, CA, USA, March 2011).

4. Dhawan, A., Ghosh, T. K. & Muth, J. F. Incorporating Optical Fiber-based Sensors into Fabrics (Materials 

Research Society Conference, Materials Research Society, Boston, MA, February 1, 2011).

5. Di Spigna, N. et al. The integration of novel EAP-based Braille cells for use in a refreshable tactile 

display (SPIE Smart Structures and Materials + Nondestructive Evaluation and Health Monitoring Ser. 7642, 

SPIE, San Diego, CA, USA, Apr 8, 2010).

6. Di Spigna, N., Chakraborti, P., Yang, P., Ghosh, T. & Franzon, P. Application of EAP materials toward a 

refreshable Braille display (SPIE Smart Structures and Materials + Nondestructive Evaluation and Health 

Monitoring, Ser. 7287, SPIE, San Diego, California, USA, Mar 26, 2009).

7. Vargantwar, P. H., Ghosh, T. K. & Spontak, R. J. Novel thermoplastic elastomeric gels as high-performance 

actuators with no mechanical pre-strain (SPIE Smart Structures and Materials + Nondestructive Evaluation 

and Health Monitoring, 2009 Ser. 7287, SPIE, San Diego, CA, USA, Mar 26, 2009).

8. Karahan, A., Vargantwar, P., Spontak, R. J. & Ghosh, T. K. Carbon Nanofiber Modified PVC as Fabric Sensor 

Composite for E-Textiles (NSF-CMMI Research and Innovation Conference, NSF-CMMI, Honolulu, 2009).

9. Krishnan, A. S., Shankar, R., Ghosh, T. K. & Spontak, R., J. Nanostructured Triblock Copolymer Network with 

Tailorable Electroactive Response (ASME 2008 Conference on Smart Materials, Adaptive Structures and 

Intelligent Systems, ASME, Ellicott City, Maryland, USA, October 2008).

10. Shankar, R., Ghosh, T. K. & Spontak, R. J. Intriguing electroactive behavior of nanostructured polymers (SPIE 

Smart Structures and Materials and NDE for Health Monitoring and Diagnostics, SPIE, San Diego, CA, USA, 

2007).

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TUSHAR K. GHOSH

(Page 10 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

11. Shankar, R., Ghosh, T. K. & Spontak, R. J. Electromechanical Response of Nanostructured Polymer at Zero 

Prestrain (SPIE Smart Structures and Materials and NDE for Health Monitoring and Diagnostics, SPIE, San 

Diego, CA, USA, 2007).

12. Sun, X., Shankar, R., Ghosh, T., Borner, H. G. & Spontak, R. Field-Driven Surface Biofunctionalization of 

Electrospun Fibers(2006 AIChE Annual Meeting, AIChE, San Francisco, CA, November 2006).

13. Ghosh, T. K., Arora, S. & Muth, J. Fiber Actuators (International Fiber Conference 2006, The Fiber Society, 

Seoul, Korea, 2006).

14. Dhawan, A., Muth, J. F., Kekas, D. J. & Ghosh, T. K. Optical nano-textile sensors based on the incorporation 

of semiconducting and metallic nanoparticles into optical fibers (Materials Research Society Conference 

Symposium S Ser. 920, Cambridge University Press, Boston, MA, 2006).

15. Ghosh, T. K., Dhawan, A. & Muth, J. Electronic Textiles Today and Potential for the Future (International 

Conference on Emerging Trends in Polymers and Textiles, IIT Delhi, New Delhi, India, 2005).

16. Batra, S. K. &Ghosh, T. K. Engineering with Fibers (Industry): Implications for Education (International 

Conference on Emerging Trends in Polymers and Textiles, IIT Delhi, New Delhi, India, 2005).

17. 17. Mohan, A., Seyam, A. M. & Ghosh, T. K. Characterization of Fiberwebs from Electrospun 

Fibers  (First International Conference of Textile Research Division, National Research Center, Cairo, 

Egypt, Cairo, Egypt, 2004).

18. Ghosh, T. K. Electronic Textiles: An Overview (2004 Spring Conference:Textile Quality Control Association, 

Charlotte, NC, USA, 2004).

19. Ghosh, T. K., Seyam, A. M. & Dhawan, A. Electronic Textiles: The Evolution and Future (7th Asian Textile 

Conference, New Delhi, India, 2003).

20. Ghosh, T. K. &Batra, S. K. Dynamic analysis of over-end unwinding from conical packages (The Fiber Society 

Fall Conference, The Fiber Society, Raleigh, NC, USA, 2003).

21. Grant, E. et al. Developing a Portable Acoustic Array on A Large-Scale E-Textile Substrate (International 

Textile Design and Engineering Conference, Emerald Group Publishing Limited, Edinburgh/Galashiels, UK, 

2003).

22. Natarajan, K., Dhawan, A., Seyam, A. M., Ghosh, T. K. & Muth, J. F. Electrotextiles - Present and 

Future (Materials Research Society Conference Ser. 736, Cambridge University Press, Boston, MA, Jan 1, 

2002).

23. Dhawan, A., Ghosh, T. K., Seyam, A. M. & Muth, J. Development of Woven Fabric-based Electrical Circuits 

(Invited) (Materials Research Society Conference Ser. 736, Cambridge University Press, Boston, MA, Jan 1, 

2002).

24. Muth, J. F. et al. Signal Propagation and Multiplexing Challenges in Electronic Textiles (Invited) (Materials 

Research Society Conference Ser. 736, Cambridge University Press, Boston, MA, USA, Jan 1, 2002).

25. Dhawan, A., Ghosh, T. K., Seyam, A. M. & Muth, J. F. Woven Fabric-Based Electrical Circuits (IFAI Expo 2002, 

Industrial Fabrics Association International, Charlotte, NC, USA, 2002).

26. Ghosh, T. K. &Batra, S. K. On Over-end Unwinding of Cylindrical Packages: A Progress Report (Textile 

Research Symposium , Kyoto, Japan, 2001).

27. Batra, S. K., Ghosh, T. K. & Zeng, Q. Dynamic Analysis of Ring Spinning: A Brief Review (Textile Science 

Conference, Liberec, Czech Republic, 2000).

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TUSHAR K. GHOSH

(Page 11 of 12)

College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

28. Huang, W. &Ghosh, T. K. Instrumentation of Online Monitoring System for Fabric Compressional 

Behavior (International Instrumentation Symposium, Seattle, 2000).

29. Huang, W. &Ghosh, T. K. Application of Filters in Textile Industry and Fibrous Filters (Filtration and 

Separations Technologies, AFS Society, Northport, AL, 2000).

30. Wensheng Huang &Ghosh, T. K. Online measurement of fabric mechanical properties: compressional 

behavior (IEEE Industry Committee Conference, IEEE, Atlanta, USA, 1999).

31. Ghosh, T. K. Development of an Instrument for the Evaluation of Biaxial Stress-Strain Response of 

Fabrics (Association of the Nonwoven Fabric Industry, INDA-TEC, Cary, NC, USA, 1998).

32. Batra, S. K., Ghosh, T. K. & Zeidman, M. I. On the Dynamic Analysis of Ring Spinning, Wool Research 

Organization of New Zealand and the Textile Institute, New Zealand, New Zealand, 1988).

Patents Issued

1. Smart Textile Sensing Systems and related Methods, U.S. patent 20170224280, Bozkurt, A., Ghosh, T., 

McKnight, M., Issued: August 10, 2017

2. Electroactive Nanostructured Polymers as Tunable Organic Actuators, U.S. patent 7,956,520, Shankar, R., 

Ghosh, T. K., Spontak, R. J., Issued: June 7, 2011

3. Fabric and Yarn Structures to Improve Signal Integrity in Fabric-based Electrical Circuits, U. S. patent 

7,348,285 B2, Dhawan, A., Ghosh, T. K., Seyam, A. M., and Muth, J. F., Issued: March 25, 2008

4. Methods and Systems for Selectively Connecting and Disconnecting Conductors in a Fabric, U. S. patent 

7,329,323 B2, Dhawan, A., Ghosh, T. K., Seyam, A. M., and Muth, J. F., Issued: February 12, 2008

5. Methods and Systems for Selectively Connecting and Disconnecting Conductors in a Fabric, U. S. patent 

6,852,395, Dhawan, A., Ghosh, T. K., Seyam, A. M., and Muth, J. F., Issued: February 8, 2005

6. Apparatus and method for biaxial tensile testing of membrane materials, U. S. patent 6,487,902, Ghosh, 

T. K., Issued: December 3, 2002.

Technical Presentations at Conferences and Symposia

More than 200 presentations in national and international conferences, including more than 60 invited and 

keynote lectures.

Consulting Activities

Albany International Co., Lorex Corporation, Lear Seating Co. United Nations Development Program, 3M 

Corporation, General Motors Corporation, Sara Lee Corporation, Tsudakoma Corporation, North Sails 

Corporation, Yupoong, Inc., TRW Corp., Monmouth University, Touch Materials

ADVISORY ACTIVITIES

Academic advising

Formally advised numerous Textile Technology, and Textile and Apparel Management undergraduates.

Informally advised many Textile Technology, Textile and Apparel Management, Textile Engineering, Materials 

Science and Engineering, and Chemical Engineering graduate students on matters regarding research 

opportunities, available/upcoming courses and professional development.

Research Advising:

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TUSHAR K. GHOSH

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College of Textiles, North Carolina State University, P. O. Box 8301, Raleigh, NC 27695,

Phone: (919) 515-6568, Fax: (919) 515-6532, Email: tghosh@ncsu.edu

Post-Doctoral Research Associates/Visiting Scholars Directed/Hosted

1991-1993 Dr. Hong Peng, Mechanics of Textile Structures

1994-1996 Dr. Zengheng Xie, Biaxial Tensile Behavior of Fabrics

1995-1996 Dr. Sanat Bandopadhyay, Characterization of Fabrics

1994-1995 Dr. Anup Bandopadhyay, Yarn Quality Characterization

1997-1998 Dr. Tae Young Park, Characterization of Geotextiles

1997 - 2000 Mr. A. Deshpande, Dynamic Analysis of Ring Spinning Balloon

2015- 2017 Mr. Huiqi Shao, Bisatable/Morphing EAP Devices

Doctoral Research Directed

Qingyu. Zeng (1995), Owens Corning S & T, Granville, OH, Nayiue Zhou (1996), Corning, Inc, NY, Ma Xiaofeng

(1997), Breed Technologies Inc., TN, Harsha Puneetha (1997), Bayer Corp., NC, Christian Koch (1999), Raoul 

Farer (1999), Freduenberg Nonwovens, Germany, Wensheng Huang (1999), Ericsson Telecommunications, 

NC, Pan Zicheng (2001), Syncsort, Inc., NJ, Kristie Phillips (2002), Cotton Inc., NC, Anuj Dhawan (2006), 

Indian Institute of Technology, New Delhi, Jeesang Huang (2006), Samsung SDI Co. Ltd., Seoul, Ravi Shankar

(2007), Intel Corp., AZ, Pruthesh Varganttwar (2009) Eastman Chemicals, TN, Saral Kalandhabhatla (2013) 

University of Rhode Island, Aylin Karahan Toprakci (2013), Yalova University, Turkey, Krishna Bala 

Subramani (2014), Enes Cakmak (2014), Suleyman Demirel University, Turkey, Xiaomeng Fang (2017), NC 

State University, Ashish Kapoor (2020), Intel Corp., Kony Chatterjee (Current), Jordan Tabor (current), 

Shuzhen Wei (Current)

Masters Research Directed

Bhupesh Dua (1991), Nike Inc. Hua Li (1989), Deying Kong (1992), Xi Qiao (1994), Prudential Investments, 

Sachin Parker (1994), Anuj Jain (1995), M. V. Rao (1993), Ana Leiderman (1996), A. S. Murthy (1994), Ford 

Motor Co., MI, Hemen Dattani (1997), Co-major IMSE, Surya Gupta (1998), Du Pont Co., Karthikeyan 

Natarajan (2002), The Limited, NY, Anuj Dhawan (2002), Duke University, NC, Cuneyt Akbay (2003), NnaoTex LLC, Istanbul, Sohil Arora (2004), Select Comfort, CO, Saurabh Chaaparwal (2004), Freduenberg 

Nonwovens, NC, Parthasarathi Chakraborti (2012), Georgia Institute of Technology, Shuzhen Wei 

(2018), Samantha Jeffrey (2018),

Graduate Student Committees

Served in numerous graduate student committees at both Ph. D. and M.S. levels.

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EXHIBIT 2

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 40 of 42 PAGEID #: 2023
List of Documents Reviewed

AQ-HawesVMacys_0005349

AQ-HawesVMacys_0005393

AQ-HawesVMacys_0005411

AQ-HawesVMacys_0005419

AQ-HawesVMacys_0005482 

AQ-HawesVMacys_0005547

AQ-HawesVMacys_0005565

AQ-HawesVMacys_0006450

AQ-HawesVMacys_0006575

AQ-HawesVMacys_0009711

AQ-HawesVMacys_0010199

AQ-HawesVMacys_0010359

AQ-HawesVMacys_0010549

AQ-HawesVMacys_0011224

AQ-HawesVMacys_0012526

AQ-HawesVMacys_0012485

AQ-HawesVMacys_0012486

AQ-HawesVMacys_0015137

AQ-HawesVMacys_0015142

AQ-HawesVMacys_0015510

AQ-HawesVMacys_0015695

AQ-HawesVMacys_0016007

AQ-HawesVMacys_0016023

AQ-HawesVMacys_0016026

AQ-HawesVMacys_0016207

AQ-HawesVMacys_0017737

AQ-HawesVMacys_0017970

AQ-HawesVMacys_0017981

AQ-HawesVMacys_0018934

AQ-HawesVMacys_0018949

AQ-HawesVMacys_0018955

AQ-HawesVMacys_0018969

AQ-HawesVMacys_0019180

AQ-HawesVMacys_0019209

AQ-HawesVMacys_0019922

AQ-HawesVMacys_0019934

AQ-HawesVMacys_0019937

AQ-HawesVMacys_0021103

AQ-HawesVMacys_0022017

AQ-HawesVMacys_0022018

AQ-HawesVMacys_0022019

AQ-HawesVMacys_0022026

AQ-HawesVMacys_0022027

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 41 of 42 PAGEID #: 2024
AQ-HawesVMacys_0022028

MACYS_0000760

MACYS_0000985

MACYS_0000986

MACYS_0000987

MACYS_0000989

MACYS_0000990 

MACYS_0000991

MACYS_0000992

MACYS_0001008

MACYS_0001334

MACYS_0001837

MACYS_0001897

MACYS_0001974

Deposition Transcript of Sara Hawes w/ Exhibits

Deposition Transcript of Larry Queen w/ Exhibits

Deposition Transcript of Sean Cormier w/ Exhibits

Report of Sean Cormier

Photographs produced by Sean Cormier

Third Amended Complaint

Case: 1:17-cv-00754-DRC Doc #: 100-3 Filed: 05/18/21 Page: 42 of 42 PAGEID #: 2025