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`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`XILINX, INC., )
` Petitioner, )
` )
`VS. ) Case IPR2013-00029
` ) Patent 5,632,545
`INTELLECTUAL VENTURES I )
`LLC, )
` Patent Owner. )
`
` **************************************************
` ORAL AND VIDEOTAPED DEPOSITION OF
` A. BRUCE BUCKMAN, M.D.
` JUNE 11, 2013
` **************************************************
`
` ORAL AND VIDEOTAPED DEPOSITION OF A. BRUCE BUCKMAN,
`M.D., produced as a witness at the instance of the
`Patent Owner, and duly sworn, was taken in the
`above-styled and numbered cause on June 11, 2013, from
`9:26 a.m. to 11:08 a.m., before Donna Wright, CSR in
`and for the State of Texas, reported by machine
`shorthand, at the law offices of HAYNES AND BOONE, LLP,
`600 Congress Avenue, Suite 1300, Austin, Texas,
`pursuant to the Federal Rules of Civil Procedure and
`the provisions stated on the record or attached hereto.
`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`XILINX, INC., )
` Petitioner, )
` )
`VS. ) Case IPR2013-00029
` ) Patent 5,632,545
`INTELLECTUAL VENTURES I )
`LLC, )
` Patent Owner. )
`
` **************************************************
` ORAL AND VIDEOTAPED DEPOSITION OF
` A. BRUCE BUCKMAN, M.D.
` JUNE 11, 2013
` **************************************************
`
` ORAL AND VIDEOTAPED DEPOSITION OF A. BRUCE BUCKMAN,
`M.D., produced as a witness at the instance of the
`Patent Owner, and duly sworn, was taken in the
`above-styled and numbered cause on June 11, 2013, from
`9:26 a.m. to 11:08 a.m., before Donna Wright, CSR in
`and for the State of Texas, reported by machine
`shorthand, at the law offices of HAYNES AND BOONE, LLP,
`600 Congress Avenue, Suite 1300, Austin, Texas,
`pursuant to the Federal Rules of Civil Procedure and
`the provisions stated on the record or attached hereto.
`
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`Page 2
` A P P E A R A N C E S
`FOR THE PETITIONER:
` Mr. David L. McCombs
` HAYNES AND BOONE, LLP
` 2323 Victory Avenue
` Dallas, Texas 75219
` (214) 651-5581
`FOR THE PATENT OWNER:
` Mr. George Quillin
` Mr. Paul Hunter
` FOLEY & LARDNER, LLP
` 3000 K Street, N.W., Suite 600
` Washington, D.C. 20007
` (202) 672-5300
` -and-
` Mr. Don Coulman
` 3150 139th Avenue, SE
` Bellevue, WA 98005
`
`ALSO PRESENT:
` Jason Lemley - Videographer
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` INDEX
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`Page 3
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` Appearances..................................... 2
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`A. BRUCE BUCKMAN, M.D.
`
` Examination by Mr. Quillin...................... 5
` Examination by Mr. McCombs...................... 31
` Further Examination by Mr. Quillin.............. 34
` Reporter's Certificate.......................... 41
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`Page 4
` THE VIDEOGRAPHER: Good morning. Here
`begins Media No. 1 in the deposition of Bruce Buckman
`in the matter of Xilinx, Inc. vs. Intellectual
`Ventures I, LLC. This case is in the United States
`Patent and Trademark office, and the case number is
`IPR2013-00029.
` Today's date is June 11, 2013, and the
`time is 9:26. This deposition is taking place at
`600 Congress Avenue, Austin, Texas. The videographer
`is Jason Lemley, appearing on behalf of Sound
`Deposition Services located at 400 Oceangate Plaza,
`Suite 400, Long Beach, California, 90802.
` Would counsel please identify yourselves
`and state who you represent?
` MR. QUILLIN: I'm George Quillin, with
`the law firm of Foley & Lardner. With me is
`Paul Hunter and Don Coulman, all on behalf of
`Intellectual Ventures.
` MR. McCOMBS: This is David McCombs. I'm
`with Haynes and Boone, and I represent Xilinx, the
`petitioner.
` THE VIDEOGRAPHER: The reporter today is
`Donna Smith. Would the court reporter please swear in
`the witness.
` A. BRUCE BUCKMAN, M.D.,
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`Page 5
`having being first duly sworn, testified as follows:
` EXAMINATION
`BY MR. QUILLIN:
` Q. Good morning, Dr. Buckman.
` A. Good morning.
` Q. Would you please state your name for the
`record?
` A. For the record, my name is
`Alvin Bruce Buckman.
` Q. You've been deposed before?
` A. Yes.
` Q. And so you understand that you're under oath
`and that your testimony this morning is being video
`recorded?
` A. I do.
` Q. What did you do to prepare for today's
`deposition?
` A. Re-read my declaration, re-read the patents
`that are cited in that declaration. That's it.
` Q. Any other documents that you reviewed?
` A. Not in direct preparation for the deposition,
`no.
` Q. About how much time did you spend preparing
`for the deposition?
` A. A couple of hours.
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` Q. Let me hand you what's been previously marked
`as Xilinx Exhibit 1001. You're familiar with this
`patent?
` A. Yes, I am.
` Q. And who is the inventor?
` A. Mr. Kikinis.
` Q. And the title of the patent?
` A. Enhanced Video Projection System.
` Q. And when was it filed?
` A. The filing date is July 26, 1996.
` Q. If you would turn to Column 1, please. Near
`the top of that Column 1, you'll see "Field of the
`Invention." Under that heading if you would read into
`the record the -- that sentence about the field of the
`invention.
` A. "The present invention is in the area of video
`projection display and pertains more particularly to
`such displays using liquid crystal displays."
` Q. And I would like to hand you what's been
`previously marked as Xilinx Exhibit 1007. Do you
`recognize this document?
` A. I do.
` Q. What is it?
` A. It's a collection of actually two documents
`from the web which comprise my curriculum vitae.
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` Q. Looking at your list of publications, does
`your CV list a publication of the term "liquid crystal"
`in the title?
` A. No.
` Q. And does your CV list any of your publications
`with the term "video projection display" in the title?
` A. No.
` Q. The same questions with regard to your
`refereed conference proceedings.
` A. No. "Liquid crystals" or "video displays" are
`not words you find in the title.
` Q. And the same pair of questions with regard to
`"Other Conference Proceedings" on Page 7 of your CV.
` A. The same answer.
` Q. I take it with regard to both of those
`questions you would -- I would get the same answer
`asking you about book chapters and reviews and
`technical reports on Pages 7 and 8?
` A. You would.
` Q. And, again, with textbooks on Page 8, nothing
`in the title that mentions "liquid crystal display" or
`"video projection display"?
` A. Nothing in the title, that's correct.
` Q. On Pages 9 and 10, "Professional Society
`Presentations," again, no mention in the CV of "liquid
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`
`crystal" or "video projection display," right?
` A. Nothing in the titles, that's correct.
` Q. And on Page 11, under "Other Presentations,"
`no mention of "liquid crystals" or "video display
`technology," right?
` A. That's correct.
` Q. You have four patents listed on Page 11 of
`your CV. None of those patents as listed on your CV
`mention "liquid crystal" or "video projection display";
`is that correct?
` A. That's also correct.
` Q. And the same with your "Research, Grants, and
`Contracts" on Page 11 and 12. No mention of "liquid
`crystal" or "video projection display," right?
` A. No mention in the title, that's right.
` Q. On your expert witness experience, your CV
`doesn't say that you've ever testified with regard to
`liquid crystals or video projection displays; is that
`right?
` A. The CV does not say that, yes, that's correct.
` Q. Your CV also does not say that you've ever
`designed a video projection system; is that correct?
` A. That's correct.
` Q. In fact, looking through the whole CV of
`Exhibit 1007, isn't it correct that it nowhere mentions
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`the term "liquid crystal"?
` A. That would be correct.
` Q. And, similarly, it -- Exhibit 1007 nowhere
`mentions the term "video projection display"; is that
`correct?
` A. That would be correct.
` Q. Have you ever testified in a legal proceeding
`about liquid crystal displays?
` A. In those lawsuits none of the principal
`subjects were liquid crystal displays, that's correct.
` Q. Your CV does not list you as a member of any
`professional organization focused on liquid crystal
`displays or video display technology; is that right?
` A. It doesn't list any society memberships
`because I'm retired from UT, and I'm no longer a member
`of any of the societies I was a member of while I was
`working.
` Q. Have you ever consulted for a company
`manufacturing video projection systems?
` A. No, no manufacturers.
` Q. Back at the time that the Kikinis patent
`application was filed back in the mid '90s, what were
`the standard reference works in the field of video
`projection display?
` A. They would have been the standard reference
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`works for optics and optical systems, works such as
`Born and Wolf, Principles of Optics; works such as
`J.W. Goodman, Introduction to Fourier Optics. These
`are two broad books which cover those fields.
` Q. The fields of video projection display --
` A. Correct.
` Q. -- and liquid crystal display?
` A. Whether they -- whether the projection works
`by liquid crystals or by some other means of modulator,
`the optics around such things would be described in
`general principle by Born and Wolf and by the Goodman
`text.
` Q. Aside from the authors of those works back in
`the mid '90s, who were the leading authorities in the
`field of video projection display?
` A. I don't know about who the authorities were in
`projection displays. The authorities in -- in the
`optical field, many different people.
` Q. What about today? Who are the leading
`authorities in this field today, the field of video
`projection display?
` A. Video projection display today is what I would
`call a mature field. People are generally not
`publishing additional new technology involving video
`projection displays. It's progressed by way of
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`Page 11
`engineering progress, smaller -- smaller projectors,
`more powerful light sources, things like that, which
`now produce the projectors, the size of books.
` Q. Let me hand you what's previously been marked
`as Xilinx Exhibit 1006. This is the declaration you
`submitted with regard to the Kikinis '545 patent,
`right?
` A. Right.
` Q. And it contains your opinions in this matter?
` A. That's correct.
` Q. On Pages 1 and 2, you reference documents that
`you have studied in preparing your declaration. Are
`there other documents not listed that you studied in
`preparing your declaration?
` A. As to documents, no.
` Q. So there aren't any other patents that you
`studied in preparing your declaration, right?
` A. That's right.
` Q. And this declaration expresses the bases for
`your opinions; is that right?
` A. Yes, it does express the bases.
` Q. You're not holding anything back from the
`patent office?
` A. I am not holding anything back from you, no.
`The --
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` Q. I'm going to hand you what's been previously
`marked as Xilinx Exhibit 1002. This is one of the
`patents you studied in preparing your declaration?
` A. Is that a question? If it is a question, the
`answer is yes.
` Q. If you would look at Column 2 of this Flasck
`patent. This is Exhibit 1002, U.S. Patent 5,108,172 to
`Flasck, F-l-a-s-c-k.
` In the paragraph of Flasck beginning at
`about Line 23, why don't you read that to yourself.
` A. Okay.
` Q. In the second sentence there beginning, "Each
`of these markers," there's a phrase "video speed
`imaging." Do you see that?
` A. Yes.
` Q. What speed is video speed?
` A. Video speed is a speed of refreshing of the
`image, the entire image, which is fast enough to be
`undetectable by the human eye, so it looks like a
`continuous -- a continuous picture. The exact number
`can vary a little bit, but it's in the order of tens of
`frames per second, typically.
` Q. Ten frames per second?
` A. Tens of frames per second.
` Q. I'm sorry. And if there were a -- is that
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`sometimes expressed as a refresh rate?
` A. Yes.
` Q. And what's the refresh rate for video speed?
` A. It would be the order of tens of frames per
`second. Since it's going to be viewed by a human,
`anything faster than tens of frames per second is not
`going to make any difference to the human eye.
` Q. So for a given frame, how many seconds or what
`fraction of a second would it be?
` A. A given frame would be there if the refresh
`rate were ten second -- ten per second, it would be
`there for a tenth of a second, and then a new frame
`would appear.
` Q. In Column 4 of Flasck, you'll see starting
`with the second paragraph it references a Figure 1. Do
`you see that?
` A. Yes. Beginning at Line 6?
` Q. Yes. That's referring to a prior art system,
`isn't it?
` A. Yes, it is.
` Q. And the next paragraph as well, starting at
`Line 25 of Column 4?
` A. That refers to another prior art projection
`system.
` Q. And the specification here on -- in Column 4
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`recounts the disadvantages of those prior art systems;
`isn't that right?
` A. Beginning at about Line 32 of Column 4, Flasck
`recounts problem -- a problem caused by the liquid
`crystal material in -- when operated in a transmissive
`mode.
` Q. And what does Flasck say about that problem?
` A. He describes the LC -- the transmissive LCD
`panels as having a polarizer on each side of the liquid
`crystal material, states that both the polarizers and
`the liquid crystal absorb light that generates heat.
`Heat is bad for the LCD panel. And the two polarizers
`absorb enough light, so he states that only about
`15 percent or less of the light is directed to the LCD
`panel. Only about 15 percent of that gets transmitted.
`And the result, he says, is low brightness because of
`the amount of light absorbed.
` Q. Okay. He characterizes that prior art's
`condition as being deleterious to the LCD panel in
`Lines 36, 37?
` A. In Line 36 and 37 he's referring to the
`absorption by the liquid crystal material, which
`generates heat. And that, he says, is the letris to
`the LCD panel. And that -- but that -- that heat is
`produced by both the absorption in the polarizers and
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`absorption in the liquid crystal itself.
` Q. Is Flasck encouraging people to use this sort
`of system or is he proposing that he has a solution to
`the problem that exists?
` A. He is proposing a different configuration of
`the liquid crystal material.
` Q. To overcome the problem?
` A. To at least reduce the amount of heat
`generated -- generated.
` Q. In Column 5 of Flasck, beginning the second
`full paragraph, about Line 21, do you see that?
` A. I'm sorry. Which line?
` Q. Starting about Line 21.
` A. Okay.
` Q. The wafer-based active matrix 46. Do you see
`that?
` A. Yes.
` Q. In the second sentence of that paragraph
`Flasck mentions that the wafer-based active matrix is
`covered by an LCD or similar characteristic material
`such as electrophoretic material. Do you see that?
` A. Yes.
` Q. What's the refresh rate of electrophoretic
`material?
` A. I don't know off the top of my head what the
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`maximum refresh rate of an electrophoretic material can
`be.
` Q. Would you believe it would be fast enough to
`be at video speed?
` A. I would believe it would be fast enough to be
`at video speed, yes.
` Q. And what's the basis for that belief?
` A. The basis for that belief is that Flasck is
`describing here a video projection system, and he's --
`he's suggesting the use of an electrophoretic material.
` Q. You say that Flasck is describing a video
`projection system. Where -- where in Flasck do you see
`a description of a video projection system?
` A. I see a video projection system, for example,
`in Figure 11 of Flasck.
` Q. And what is it about Figure 11 that you
`believe communicates the notion of a video projection
`system?
` A. Basically it comes from the box labeled
`"Interface" in Figure 11, but numbered 118, which is
`also called a -- I believe I'm recalling correctly here
`by memory -- a television or computer interface
`electronics elsewhere in the patent.
` Q. You may be thinking of Column 7, Lines 32, 33?
` A. That simply describes an electronic interface.
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`If I can review --
` Q. Sure.
` A. -- the declaration for the moment, I think I
`can find you the spot I'm referring to.
` Q. Well, but merely an electronic interface
`wouldn't communicate video?
` A. An electronic interface, that terminology by
`itself doesn't rule out the communicating of video. A
`video interface would be electronic in nature.
` Q. Okay.
` A. Okay. Your original question was you wanted
`the source of my opinion that this is a video system.
`Backing up from Figure 11 to Figure 9, I note the
`Box 118, which carries the same numerical designation
`as the box simply labeled "Interface" later on in
`Figure 11.
` If we back up to Figure 9, we have that
`box, the same box, labeled "TV" or "Computer Interface
`Electronics" than the presence of either TV or computer
`interface. Those words within that box signifies to me
`and to somebody of ordinary skill in the art that this
`system is designed for video operation.
` Q. Why is that?
` A. Well, typical televisions or computers which
`display moving images operate at video speeds. You can
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`look at those and you don't see the visible flicker
`from frame to frame. The frame rate is fast enough so
`that the human eye doesn't perceive it as frames being
`shifted.
` Q. And that's distinct from -- from what, from
`what other display; from a static display?
` A. I'm not sure what you mean by "static
`display." Even displays which do essentially a slide
`show where one sees the -- the flipping from slide to
`slide, those are not static for all time; that is,
`dynamic changes are made. So I'm not sure what you
`mean by a "static display." But the designation in
`Figure 9 within the Box 118 says to me that this is a
`dynamic display, and it's dynamic enough to be
`perceived like a television picture.
` Q. There are computer -- there are computer
`interface electronics, though, that would not be at
`video speed; is that right?
` A. Such computer interface electronics
`undoubtedly exist, although it would seem absurd to me
`to apply that kind of computer interface electronics to
`something which is clearly supposed to deliver to the
`human eye an image which moves. It doesn't make sense
`to use some other member of this broad class of
`computer interface electronics in connection with a
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`system such is shown in Figure 9 or 11 of Flasck.
` Q. You believe an electrophoretic material would
`accomplish that?
` A. I have no reason not to believe that it would.
` Q. Let's turn our attention to another patent.
`I'm handing you what's been previously marked as Xilinx
`Exhibit 1003. This is U.S. Patent 5,264,951 to
`Takanashi. And you're familiar with this patent; is
`that correct?
` A. Yes.
` Q. If you would, turn to Figure 17 of Takanashi.
` A. Okay.
` Q. And then while you have that in front of you,
`look back at your declaration, Exhibit 1006. And I
`believe it's Paragraph 43.
` A. I'm there.
` Q. Okay. And then also the previous paragraph in
`your declaration, Paragraph 42. Figure 17 illustrates,
`and your declaration refers to, sets of elements;
`ECB, PL2, SLM. And there are three sets of those --
`three component elements in Takanashi, right?
` A. That's correct.
` Q. With regard to those three sets, is each one
`identical to the other?
` A. I would have to look to see if they were
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`described as exactly identical. They're at least
`identical in function.
` Q. Because they produce the same color light?
` A. Not that identical, not the same -- not the
`same color light. These -- these modules that you are
`referring to, including the -- I'll just use their
`letter designations; ECB, PL2, and SLM.
` To answer the first part of your
`question, these modules do not produce any light in and
`of themselves.
` Q. How does the one set differ from another?
` A. They differ from each other in the color of
`light that they process.
` Q. Now, you say in Paragraph 43 that -- let me
`back up.
` Is it correct to say that Takanashi
`refers to those elements as the wavelength selection
`filter?
` A. Those elements, I don't think that they are
`wavelength selection filters. According to Figure 17
`of Takanashi, you have a three-color optical separation
`system, and that's what plays the role of a filter.
` Q. If you look at Column 16 of Takanashi, please,
`beginning at, say, Line 29, what is it that Takanashi
`refers to as the wavelength selection filter?
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` A. He collectively refers to the polarizers, the
`liquid crystal elements, and the modulator elements as
`forming the wavelength selection filter.
` Q. Turning back to Paragraph 43 of your
`declaration, you say "these elements," meaning the
`elements referred to in Paragraph 42, I take it, are
`placed in the beam paths to encode the beams with image
`information. Do you see that?
` A. I do.
` Q. How would this image information get written
`into the wavelength selection filter?
` A. It gets written by means of the spatial light
`modulators. They encode the spatial information on
`each of the individual color beams.
` Q. Is it correct that the write light,
`w-r-i-t-e -- the write light controls what image is
`formed in the wavelength selection filter?
` A. Tell me where you're referring to "write
`light" within the patent so I can get some context here
`and answer your question.
` Q. Well, on the -- on the cover of the patent on
`the bottom there's a drawing figure.
` A. Right.
` Q. On the far left-hand side of that drawing
`figure there is two letters, "WL." Do you see that?
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`
` A. Yes.
` Q. What is -- what do those letters mean?
` A. I'm going to have to look at the text
`describing Figure 8 where things are numbered. Okay.
`It's the write light that's addressing the spatial --
`various spatial positions within the spatial light
`modulator. So it's controlling the operation of the
`spatial light modulator.
` Q. Is it correct that the write light controls
`what image is formed in the wavelength selection
`filter?
` A. It controls what parts of the spatial light
`modulator are configured so as to either blank out the
`light or not blank it out. So it does control the
`image within each color part of this overall wavelength
`selection filter.
` Q. Let me hand you what has been previously
`marked as Xilinx Exhibit 1004. This is U.S. Patent
`No. 5,287,131 to Lee. You're familiar with this patent
`also; is that correct?
` A. Yes.
` Q. Have you had a chance to look through it?
` A. Yes.
` Q. Looking at Column 3, starting about Line 25,
`26, "Lights Shutters 14R, 14G, 14B."
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` A. I see that.
` Q. Are Lee's Shutter Elements 14R, 14G, 14B
`controlled by a write light signal?
` A. Lee doesn't mention a write light signal. In
`Lee the shutters are controlled by means of an
`electronic signal, which addresses various rows and
`columns in the matrix and forms the image.
` Q. So Lee's Shutter Elements 14R, 14G, and 14B
`are not controlled by a write light signal?
` A. They're not controlled by a write light
`signal, that's correct. However, they accomplish a
`similar purpose.
` Q. Does Lee's Shutter Controller 19 emit a write
`light?
` A. No, Lee's shutter controller does not emit a
`write light.
` Q. How does Lee's shutter work?
` A. At the bottom of Column 3, beginning Line 59,
`Lee states that, "The light beams of colors red, green,
`and blue are successively reflected from the reflection
`type Liquid Crystal Panel 11 according to a color
`driving signal."
` This color driving signal is what
`controls the shutter matrixes in Lee.
` Q. Figure 3 of Lee depicts what, the color wheel?
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` A. It says Figure 3 is a view of a shutter used
`as a light filter of the present invention.
` Q. Would a person of skill in the art looking at
`Figure 3 regard that as a color wheel?
` A. It's a rotating color filter -- I guess you
`could call it a -- a color wheel. It passes red,
`green, and blue according to different segments.
` Q. So how does that work? How does a color wheel
`work in projection display technology?
` A. Well, if you put it in front of a write light
`source and allow it to rotate you'll have red light
`coming through for part of the time, green light coming
`through for part of the time, and blue light coming
`through for part of the time.
` Q. Is the frequency of the rotation of that color
`wheel important in display technology?
` A. It states at Line 35 that the frequency is
`under a 30th of a second, which would mean that you had
`these color changes in this -- this particular
`embodiment of the invention occurring over intervals of
`time, which are fast enough so that the human eye would
`not perceive the changing of -- of the colors.
` Q. Would that wheel need to be rotating at a
`constant frequency?
` A. For the embodiment of the invention described
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`in this section you're referring to; that is, Column 3,
`it would need to rotate at a frequency which was
`compatible with the rest of the electronics. It would
`need to be synchronized. Most likely, it would be
`designed to operate at a constant frequency.
` Q. Do you believe that a color wheel controller
`is a video controller?
` A. A color wheel controller is not a video
`controller. It might be part of an overall video
`controller, but it's not a video controller by itself.
` Q. Do some projectors using a color wheel operate
`at a variable frequency?
` A. I can't think of a reason that they should,
`but some may.
` Q. If you took the shutter signals from Lee's
`Shutter Controller 19 and put it into Takanashi's
`wavelength selection filter, would you be able to form
`an image?
` A. Excuse me. Can we break?
` Q. Certainly.
` THE VIDEOGRAPHER: Going off the record.
`The time is 10:31.
` (Brief interruption)
` THE VIDEOGRAPHER: Back on the record.
`The time is 10:32.
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`Page 26
` Q. (BY MR. QUILLIN) Before you received the
`phone call you were contemplating the question I had --
`I had asked you. Do you have in mind that question?
` A. Can you rephrase or can you repeat it,
`please --
` Q. Sure.
` A. -- or have it read back, however you would
`like to do it.
` Q. Sure.
` MR. QUILLIN: I'll have the reporter read
`it back.
` (The requested testimony was read back)
` THE WITNESS: In principle, you would be
`able to. You might have to adjust voltage levels,
`speeds, and so on, because the -- the modulators might
`be physically different. But, in principle, if someone
`knew what kind of signal voltages, voltage levels,
`frequencies, et cetera that the modulator in Takanashi
`expected and modified the signals coming out of Lee's
`Controller 19 accordingly, you could do that. It's --
`it's a matter of component capability. I'm not
`asserting that you could simply take one and wire it to
`the other without making any changes in it.
` Q. (BY MR. QUILLIN) You've never designed such a
`system; is that right?
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`
` A. I designed many parts of it. I haven't
`designed a projection system.
` Q. Have you ever -- have you ever designed a
`system that puts Takanashi's wavelength selection
`filter into Lee to act as a shutter or to replace the
`shutter, the color wheel of Lee?
` A. In my declaration when I talk about Lee, I'm
`referring to the embodiment described at the beginning
`of Column 4, Figure 2, a second embodiment of the
`invention. And the second embodiment of the -- the
`second embodiment of the invention, okay, it still uses
`the -- the color wheel, but the filters are actual
`filters that are placed in the system that -- that are
`present in Figure 2.
` Q. So the answer to my question is -- is no?
` A. The answer to your question is no, yes.
` MR. QUILLIN: Well, we've been going a
`little more than an hour. Why don't we take a break.
` THE VIDEOGRAPHER: Going off the record.
`The time is 10:36.
` (Recess from 10:36 a.m. t
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