A Standard Document providing a sample direct examination outline for an accused infringer's invalidity expert in a patent infringement trial. This model outline addresses the expert's background and qualifications, the asserted patent, the relevant technology and prior art, alleged commercial embodiments, anticipation, obviousness, written description, enablement, and indefiniteness, as well as opinions supporting the accused infringer's damages theories. This Standard Document has integrated drafting notes with important explanations and drafting tips.