A sample direct examination outline for an accused infringer's non-infringement expert at trial. This model outline addresses the expert's background and qualifications, the asserted patent, the relevant technology, the accused product, and the expert's opinions rebutting literal infringement, infringement under the doctrine of equivalents, divided infringement, and indirect infringement. The outline also includes optional sections on commercial embodiments and technical opinions supporting the accused infringer's damages theories. This Standard Document has integrated drafting notes with important explanations and drafting tips.