A Checklist of topics to cover during the direct examination of an accused infringer's non-infringement expert at trial. The Checklist covers the expert's background and qualifications, a tutorial explaining the asserted patent, relevant technology, and accused product, a rebuttal of the patent owner's allegations regarding literal infringement, infringement under the doctrine of equivalents, induced and contributory infringement, divided infringement, and alleged commercial embodiments, as well as opinions supporting the accused infringer's damages theories.