Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 1 of 26 Page ID #:543
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 2 of 26 Page ID #:544
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`1
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` 1 ________________________________________
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` 2 IMPORTANT NOTICE
`
` 3 AGREEMENT OF PARTIES
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` 4
` We, the party working with rough draft
`transcripts,
` 5 understand that if we choose to use the rough draft
` screen or the printout, that we are doing so with
` 6 understanding that the rough draft is an
` uncertified copy.
` 7 We further agree not to share, give, copy, scan
`or
` fax or in any way distribute this rough draft in
`any
` 8 form (written or computerized) to any party.
` However, our own experts, co-counsel, and staff
`may
` 9 have LIMITED INTERNAL USE of same with the
` understanding that we agree to destroy rough draft
` 10 and/or any computerized form, if any, and replace
`it
` with the final transcript up its completion.
` 11
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` 12
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` 13 ** ATTORNEYS' EYES ONLY**
`
` 14 WITNESS: JOHN DEMOS
` DATE: SEPTEMBER 22, 2017
` 15
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` 16 REPORTER NOTE:
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` 17 Since this deposition has been in rough draft
`form,
` please be aware that there may be a discrepancy
` 18 regarding page and line number when comparing the
` rough draft, and /or rough draft disk/CD with the
` 19 final transcript.
` Also please be aware that the uncertified rough
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 3 of 26 Page ID #:545
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` 20 draft transcript may contain untranslated steno,
` reporter notes in asterisks, misspelled proper
` 21 names, incorrect or missing Q/A symbols or
` punctuation, and/or nonsensical English word
` 22 combinations. All such entries will be corrected
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` 1
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` 2 THE VIDEOGRAPHER: Begins videotape
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` 3 Number 1 in the deposition of John Demos in
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` 4 the matter of Document Security Systems,
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` 5 Incorporated v. Cree, Incorporated. This is
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` 6 filed in the In the United States District
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` 7 Court for the Central District of California
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` 8 Southern Division. The Case Number is
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` 9 2:17-CV-04263JVS-JCG. Today date is
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` 10 September the 22nd, 2017. And the time on
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` 11 the video monitor is 9:53 a.m. the video
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` 12 operator today is Trae Howard ton of case
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` 13 works.
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` 14 This deposition is taking place at 4242
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` 15 Six Forks Road in Raleigh, North Carolina.
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` 16 If counsel will please introduce
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 4 of 26 Page ID #:546
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` 1 about five years ago. Was that when you were
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` 2 still at Scenara?
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` 3 A. That's correct.
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` 4 Q. Okay. And where geographically -- where
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` 5 are you based within Cree?
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` 6 A. In Durham, North Carolina.
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` 7 Q. In addition to its facilities in North
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` 8 Carolina, Cree also operates a facility in
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` 9 California; is that correct?
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` 10 A. That's correct.
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` 11 BY MR. LEDAHL:
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` 12 Q. And is the facility located in Gilead?
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` 13 A. That is right.
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` 14 Q. How many people work at the Gilead
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` 15 facility?
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` 16 A. Approximately 30.
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` 17 Q. How long has that facility been open?
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` 18 A. I don't know.
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` 19 Q. Has it been operating for the entire
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` 20 time you've worked at Cree?
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` 21 A. Yes.
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` 22 Q. What's the general function or purpose
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` 23 of the Gilead facility?
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` 24 A. Cree's Gilead facility is involved in
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` 25 advanced research and a development, designing
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 5 of 26 Page ID #:547
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`8
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` 1 technology for Cree.
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` 2 Q. When you say "designing technology for
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` 3 Cree," can you explain what you mean by that?
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` 4 A. Sure. They're involved in research and
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` 5 development at a higher level than, say, Cree's
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` 6 product engineers in Durham. They do research
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` 7 that the related to technology that may or may not
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` 8 find its way into Cree products years down the
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` 9 road.
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` 10 Q. What -- when you say products -- excuse
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` 11 me. When you say research related to technology
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` 12 that may or may not find its way into Cree
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` 13 products down the road, am I understanding
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` 14 correctly that the research that's performed at
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` 15 the California facility does make it into some
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` 16 Cree products or am I misunderstanding?
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` 17 A. The research done at SBTC includes
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` 18 technology areas that would work -- now, maybe the
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` 19 best way to do it would be to give an example.
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` 20 Q. Sure. Go ahead. And just to be clear,
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` 21 for the record, you mentioned SBTC. Am I correct
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` 22 that's the Santa Barabara Technology facility or
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 6 of 26 Page ID #:548
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` 17 positives of occupancies.
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` 8 Q. Am I correct that researchers at Cree's
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` 9 SBTC facility have also done work in connection
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` 10 with development of lighting products and
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` 11 incorporating Cree LEDs into, for example, a
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` 12 design lightbulb fixture?
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` 13 MR. HARPER: Object to form.
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 7 of 26 Page ID #:549
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` 14 A. The SBTC research team has done research
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` 15 on a wide variety of products ranging from LED
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` 16 chips to LED lighting products LED.
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` 17 BY MR. LEDAHL:
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` 18 Q. In fact, SBTC -- excuse me, the SP --
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` 19 SBTC team has done research on incorporating
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` 20 Cree's XLamp XB-D products into a design bulb; is
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` 21 that correct.
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` 22 MR. HARPER: Object to form.
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` 23 A. I'm not aware of the exact component or
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` 24 the exact product that you described there.
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` 25 BY MR. LEDAHL:
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`12
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` 1 Q. Are you familiar with all of the various
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` 2 projects that the SBTC team has done over, say,
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` 3 the past five years?
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` 4 A. I'm not familiar with every project
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` 5 they've worked on. I am familiar with the general
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` 6 research and development they're doing during the
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` 7 time line [ 13:13.
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` 8 Q. What's the organizational structure?
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` 9 You mentioned there are approximately 30 employees
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` 10 at the SBTC. Is there a person in charge, a
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 8 of 26 Page ID #:550
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` 8 BY MR. LEDAHL:
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` 9 Q. Mr. Demos, is this a copy of the
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` 10 declaration that you submitted in this case that
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` 11 will be marked as Exhibit 1?
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` 12 A. It appears to be, yes.
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` 13 Q. And how did you come to prepare this
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` 14 declaration?
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` 15 A. I worked with counsel in drafting the
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` 16 declaration.
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` 17 Q. And is that counsel at Jones Day?
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` 18 A. Correct.
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` 19 Q. Did you consult anyone at SBTC in
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` 20 preparing your declaration?
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` 21 A. I did not.
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` 22 Q. Did you consult anyone at Cree in
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` 23 preparing this declaration?
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` 24 A. I did.
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` 25 Q. Who at a Cree did you consult?
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`14
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` 1 A. I worked with Julio Garceran and Sean
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` 2 Piles.
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` 3 Q. Can you spell Garceran for me?
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` 4 A. G-A-R-C-E-R-A-N.
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 9 of 26 Page ID #:551
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` 2 A. Sean was an ad agent.
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` 3 Q. I see.
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` 4 A. He is an ad agent.
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` 5 Q. Did you speak with or consult with any
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` 6 engineering staff at Cree in connection with
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` 7 preparing your declaration?
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` 8 A. I did not.
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` 9 Q. If you could turn in your declaration to
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` 10 page 3. There's a paragraph 8 that carries over
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` 11 from -- actually, we'll start at page 2.
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` 12 Paragraph 8 that carries over from page 2 to 3.
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` 13 You -- you identified someone at the end
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` 14 of page 2 on paragraph 8 named Charles Burnside.
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` 15 Who is that?
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` 16 A. Charles Burnside is in charge of finance
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` 17 with respect to our LED chip and component
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` 18 business.
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` 19 Q. Did you speak to Mr. Burnside in
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` 20 preparing your declaration?
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` 21 A. I did not.
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` 22 Q. How did you conclude that Mr. Burnside
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` 23 had the knowledge that you describe here in your
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` 24 declaration?
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` 25 A. So as we discussed at the beginning of
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` 24 A. So Charles Lesko is in charge of sales
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` 25 with respect to LED chips and components.
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`17
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` 1 Q. And Mr. Lesko, did you speak to him in
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` 2 connection with preparing your declaration?
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` 3 A. I did not.
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` 4 Q. Who is Craig Hardin at Cree?
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` 5 A. Craig's in charge of marketing for our
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` 6 LED chip and component business.
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` 7 Q. Did you speak to Mr. Hardin in
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` 8 connection with preparing your declaration?
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` 9 A. I did not.
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` 10 Q. Who is Chris -- is it Hussell?
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` 11 A. It is Hussell.
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` 12 Q. Who is that?
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` 13 A. Chris is one of the lead engineers and
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` 14 research and development people in our LED
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` 15 component business.
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` 16 Q. Did you speak to Mr. Hussell in
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` 17 connection with preparing your declaration?
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` 18 A. I did not.
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` 19 Q. Who is Jesse Reiherzer. Is that how you
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` 20 say it?
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 11 of 26 Page ID
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` 21 A. I believe if you ask ten people at Cree
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` 22 you may get tenth different pronunciations of his
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` 23 last name but we'll go with that. Jesse is
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` 24 another engineer that works on LED components. He
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` 25 leads a group of engineers there. Mr. Hussell
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`18
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` 1 reports to Jesse.
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` 2 Q. Did you speak to Mr. Reiherzer in
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` 3 preparing your declaration?
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` 4 A. I did not.
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` 5 Q. And who is Colin Blakely?
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` 6 A. Colin Blakely, similar to Mr. Hussell,
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` 7 is another one of the lead engineers related to
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` 8 the product development of Cree's LED component
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` 9 products.
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` 10 Q. And can you explain what his
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` 11 relationship is to Mr. Reiherzer and Mr. Hussell?
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` 12 A. Colin reports up either directly or
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` 13 indirectly to Jesse.
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` 14 Q. Did you speak to Mr. Blakely in
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` 15 preparing your declaration?
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` 16 A. I did not.
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` 17 Q. Which -- well, strike that.
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 12 of 26 Page ID
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` 15 the development of Cree's XLamp product?
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` 16 MR. HARPER: Object to form.
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` 17 A. Again, Santa Barbara, SBTC, is not
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` 18 responsible for product design. They're
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` 19 responsible for advanced research and development
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` 20 that may or may not end up in the products.
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` 21 BY MR. LEDAHL:
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` 22 Q. Okay. Did anybody at the Santa Barbara
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` 23 Technology Center work on research and development
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` 24 that ended up in any of Cree's XLamp products?
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` 25 MR. HARPER: Object to form.
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`20
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` 1 A. I don't know that specifically.
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` 2 BY MR. LEDAHL:
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` 3 Q. Are you familiar with Cree's CLM series
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` 4 products?
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` 5 A. I am.
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` 6 Q. Did -- what role did Mr. Hardin, Mr. --
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` 7 excuse me. What role did Mr. Hussell, Reiherzer
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` 8 or Blakely have in the development of any of
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` 9 Cree's CLM series products?
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` 10 MR. HARPER: Object to form.
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` 11 A. I don't know the specifics of their
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` 12 involvement at that granular a level of product.
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` 13 BY MR. LEDAHL:
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` 14 Q. Do you know if any of the work done in
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` 15 the Cree SBTC was incorporated into Cree's CLM
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` 16 series products?
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` 17 A. Again, similar to before, our SBTC
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` 18 research and development center develops
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` 19 technology that may or may not end up in these
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` 20 products.
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` 21 Q. So you don't know one way or the other
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` 22 whether technology that was developed at SBTC is
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` 23 in the CLM products?
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` 24 A. "Whether technology developed," as in
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` 25 the CLM products; do I understand correctly?
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`21
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` 1 Q. That was my question, yes,
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` 2 A. So as we said, they've done research and
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` 3 development over time ranging from LED chips to
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` 4 lighting. Whether an LED chip exists that may
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` 5 have -- whether something that they developed
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` 6 later got incorporated into an LED chip design,
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` 7 and that LED chip ended up in a product, I don't
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` 8 know specifically, but I am not aware of any
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` 9 product development done at SBTC.
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` 10 Q. Does SB -- SBTC do product testing?
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` 11 A. I'm not aware of any.
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` 12 Q. Does SBTC test potential products?
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` 13 A. I'm not aware of anything for
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` 14 product-wise. They test the technology they
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` 15 develop.
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` 16 Q. Okay. Now, we looked at a number of
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` 17 individuals in paragraph 8 from your
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` 18 declaration -- or went through a number of
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` 19 individuals. Am I correct that all of those
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` 20 individuals are current Cree employees?
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` 21 A. Yes, they are.
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` 22 Q. Are you familiar with Cree's SMD series
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` 23 products?
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` 24 A. Yes.
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` 25 Q. And what was the role of Mr. Hussell,
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`22
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` 1 Mr. Reiherzer and Mr. Blakely in developing Cree's
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` 2 SMD series products?
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` 3 A. Same answer as the other product.
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` 4 Q. Okay. Are you familiar with Cree's CLA
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` 5 series products?
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 15 of 26 Page ID
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` 6 A. CLA?
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` 7 Q. Yes.
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` 8 A. Off the top of my head, I don't remember
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` 9 the CLA as much.
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` 10 Q. For example, a CLA2 Series White or a
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` 11 CLA2 Series Color LED product?
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` 12 A. I don't recall that the CLA product
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` 13 designation. I have CLMs, CLX.
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` 14 Q. But not CLA?
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` 15 A. Not that I recall right now.
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` 16 Q. Okay. What about CLP?
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` 17 A. CLP is a product that I'm aware of
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` 18 currently.
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` 19 Q. Would your answers about what
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` 20 Mr. Hussell, Mr. Reiherzer and Mr. Blakely's
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` 21 involvement were in developing the CLP products be
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` 22 the same as those we went through, SMD or XLamp or
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` 23 CLM Series products?
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` 24 A. That is correct.
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` 25 Q. And is that also true for the CLX series
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` 1 products?
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` 2 A. Correct.
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 16 of 26 Page ID
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` 13 designed by our bulb team in Durham by David
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` 14 Power.[
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` 15 Q. What role, if any, did people at the
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` 16 Santa Barbara Technology Center have in developing
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` 17 any of Cree's bulb designs over time?
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` 18 A. So the Cree bulbs, the final product
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` 19 sold, was designed in Durham by our bulb team, our
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` 20 consumer products team.
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` 21 Q. What role, if any, did people at the
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` 22 Santa Barbara Technology Center have in developing
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` 23 any of Cree's bulb designs?
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` 24 A. So that -- the SBTC team, similar to
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` 25 before, did engage in research and development
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`29
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` 1 related to LED products, including LED bulbs.
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` 2 Q. Do you have any more specific
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` 3 understanding than what you just gave of their
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` 4 role?
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` 5 MR. HARPER: Object to form.
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` 6 A. I do not.
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` 7 BY MR. LEDAHL:
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` 8 Q. Okay. How did you determine that
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` 9 Mr. Hussell had information that would be relevant
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`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 17 of 26 Page ID
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` 10 to this lawsuit?
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` 11 A. So as we discussed in part of my role at
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` 12 Cree is to deal with litigation matters, and on
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` 13 the previous litigation matters involving LED
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` 14 components, including the packaged LEDs as we
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` 15 discussed them, the accused products in this case,
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` 16 I worked with Mr. Hussell -- Dr. Hussell, excuse
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` 17 me -- on understanding the design and the work of
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` 18 art of LED components.
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` 19 Q. When you say in connection with past
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` 20 cases, which cases was that?
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` 21 A. So Mr. Hussell would have been involved
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` 22 in the Harvatech litigation, the [Kingbright
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` 23 litigation, the ITC case. I know -- I don't
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` 24 remember off the top of my head for sure. I don't
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` 25 recall if he was involved in the other cases or
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`30
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` 1 not.
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` 2 Q. In the Harvatech case, what Cree
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` 3 products were at issue in that case?
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` 4 A. There are a couple of Harvatech cases
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` 5 here, so --
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` 6 Q. Well --
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` 1 products, LED components that would meet those
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` 2 characteristics.
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` 3 Q. What Cree products were identified as
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` 4 domestic industry products in the ITC litigation?[
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` 5 A. I don't remember off the top of my head.
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` 6 Q. So is it fair to say you don't know if
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` 7 any of the Cree products that were identified in
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` 8 the ITC litigation are also accused products in
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` 9 this case?
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` 10 A. I can't say that with certainty.
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` 11 Q. What -- where was the Harvatech
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` 12 litigation, geographically, what court was that
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` 13 in?
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` 14 A. When Cree was a plaintiff, the case was
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` 15 in the Western District of Wisconsin.
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` 16 Q. Did Mr. Hussell testify in that case?
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` 17 A. He did not. That case did not go to
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` 18 trial.
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` 19 Q. Where was the King bright case?
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` 20 A. In the western distribute of Wisconsin.
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` 21 Q. Did Mr. Hussell testify in that case?
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` 22 A. He did not because that case did not go
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` 23 to trial either.
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` 24 Q. Did he provide deposition testimony to
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` 25 your recollection?
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` 15 don't anticipate taking a lot more time. On
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` 16 the video record and to have that transcribed
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` 17 and that that will serve as a transcript for
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` 18 the deposition which will be subsequently
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` 19 transcribed.
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` 20 MR. HARPER: That's correct.
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` 21 BY MR. LEDAHL:
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` 22 Q. Mr. Demos, I want to go back -- I think
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` 23 you still have Exhibit 1 in front of you, your
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` 24 declaration; is that right?
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` 25 A. I do.
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`45
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` 1 Q. Okay. If you could look at paragraph 9
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` 2 of that declaration.
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` 3 A. Yes.
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` 4 Q. You write that "Cree is not presently
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` 5 aware of any material evidence concerning the
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` 6 production, manufacture, sale or marketing of
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` 7 accused products located in the SBTC facility."
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` 8 Do you see that?
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` 9 A. I do see that.
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` 10 Q. What research or analysis did you
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` 11 perform in order to make the statement that's
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` 12 reflected in paragraph 9?
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` 13 A. So what I did there was use the
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` 14 knowledge that I have of my almost 4 years at Cree
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` 15 involved in the various patent -- excuse me, the
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` 16 various patent matters from licensing to
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` 17 litigation to patent prosecution and my knowledge
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` 18 of where things are and where things have been
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` 19 collected from in the past in litigation and
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` 20 things of that nature to know that with respect to
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` 21 the production, manufacture or sale and marketing
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` 22 of accused products, we're not aware of any in the
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` 23 SBTC facility.
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` 24 Q. And when you say where things have been
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` 25 collected from, are you referring to collection of
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`46
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` 1 documents for production in litigation?
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` 2 A. Correct.
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` 3 Q. Have you ever inquired as to whether --
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` 4 well, strike that.
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` 5 And the litigation you're referring to
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` 6 is the litigation you've talked about previously
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` 7 today?
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` 8 A. Correct.
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` 9 Q. Okay. Do you know one way or the other
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` 10 whether materials were ever collected from anyone
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` 11 at the SBTC facility in any litigation other than
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` 12 matters you've been involved with?
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` 13 A. Can you restate that question?
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` 14 Q. Sure. You've described certain
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` 15 litigation matters you've been involved with. Am
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` 16 I correct in assuming that Cree has had other
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` 17 litigation matters over the years, both before
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` 18 your time and also during your time at Cree?
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` 19 A. Correct.
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` 20 Q. And are you aware one way or the other
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` 21 of whether in any of those other litigation
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` 22 matters that you were personally involved with any
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` 23 materials or information, have been collected from
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` 24 the SBTC facility or from people who worked there?
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` 25 A. I'm aware of collections from the SBTC
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`47
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` 1 with respect to litigation occurring.
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` 2 Q. What collections from SBTC have been
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` 3 done that you're aware of?
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` 4 A. I don't recall the specifics, but I
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` 5 recall collections being made with respect to the
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` 6 ITC case, for example. Some of the patents
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` 7 involving LED chip -- LED chips in that case. The
`
` 8 inventors were at SBTC.
`
` 9 Q. Any other instances?
`
` 10 A. None that I recall specifically.
`
` 11 Q. And would it be fair to say that you
`
` 12 don't know one way or the other if materials were
`
` 13 collected from SBTC for litigational matters that
`
` 14 were taking place before you came to Cree?
`
` 15 A. I'm aware that collections had been made
`
` 16 at SBTC prior to my time at Cree.
`
` 17 Q. Do you know what context those were
`
` 18 made?
`
` 19 A. I don't know any of the circumstances
`
` 20 associated with them.[
`
` 21 Q. Have any individuals from SBTC testified
`
` 22 in litigation involving Cree to your knowledge?
`
` 23 A. Yes.
`
` 24 Q. Who are you aware of?
`
` 25 A. I'm aware of a deposition of Eric Tarsa,
`
`
`48
`
` 1 T-A-R-S-A.
`
` 2 Q. Who is Eric Tarsa?
`
`
`
`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 23 of 26 Page ID
` #:565
`
` 16 Once we've established those, we then send our LED
`
` 17 chips to China for singulation -- which is
`
` 18 basically taking a waif of LED chips and chopping
`
` 19 it into individual LED die and then those die are
`
` 20 packaged in China to create the finished product.
`
` 21 Q. Now, when you said there's a production
`
` 22 run of the LED component package, are you -- maybe
`
` 23 you can get into that a little bit deeper. Are
`
` 24 you suggesting that there's a -- that the packaged
`
` 25 device is made in Durham and is that the test run
`
`
`53
`
` 1 or are you describing something different?
`
` 2 A. A packaged device is made in Durham as a
`
` 3 test run.
`
` 4 Q. As a test run. And then once those
`
` 5 procedures are established, that process then goes
`
` 6 forward in China with additional devices for the
`
` 7 same model; is that how -- am I understanding
`
` 8 correctly?
`
` 9 A. The packaging then, once we've
`
` 10 established the procedure, is then done in China.
`
` 11 Q. I see. So the actual manufacturing of
`
` 12 the finished actual product is completed in China
`
`
`
`Case 2:17-cv-04263-JVS-JCG Document 30-2 Filed 09/25/17 Page 24 of 26 Page ID
` #:566
`
` 13 for these devices that are listed in paragraph 6?
`
` 14 A. The final product is done in China with
`
` 15 the underlying components, the LED die that's made
`
` 16 in Durham. The LED die that's made in Durham
`
` 17 that's then shipped there and then the -- you
`
` 18 know, the encapsulate may come from another source
`
` 19 and other aspects of the LED component.
`
` 20 Q. When you say the encapsulate may come
`
` 21 from another source, are you -- are you referring
`
` 22 to the supplier or where the process of the
`
` 23 encapsulation is done?
`
` 24 A. I'm referring to the supplier.
`
` 25 Q. Okay.
`
`
`54
`
` 1 A. The process of encapsulation is done in
`
` 2 China.
`
` 3 Q. And just so I understand, sort of the
`
` 4 break down in the manufacturing process that
`
` 5 you've described, so the LED die, that refers to
`
` 6 the semiconductor chip that ha
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