What is the test for invoking the word "sham" in the context of perjury?

MultiRegion, United States of America

The following excerpt is from Zapata v. Neil Jones Food Co., Case No. 1:14-cv-02027-EPG (E.D. Cal. 2016):

be invoked only if a district court makes "a factual determination that the contradiction was actually a sham" and "the inconsistency between a party's deposition testimony and subsequent affidavit ... [is] clear and unambiguous." Van Asdale v. Int'l Game Tech., 577 F.3d at 998-999.

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