UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CERTIFIED copv
`
`) >
`
`XILINX,
`
`INC.,
`
`VS.
`
`) CASE:
`
`IPR20l3-00029
`
`) Patent 5,632.545
`
`INTELLECTUAL VENTURES I
`
`LLC,
`
`Patent Owner.
`
`)
`
`)
`
`)
`
`‘A9r~)rv\-~k*v|r~):~k1lv*~k*~Ir*~k~k~)r~)r*~k-Jr~k******~Jr********~k*-k~k**k*****~k**ir~k**~k
`
`
`
`ORAL AND VIDEOTAPED DEPOSITION OF
`
`A. BRUCE BUCKMAN
`
`Owner, and duly sworn, was taken in the above—styled and
`
`numbered cause on October 8, 2013,
`
`from 9:13 a.m.
`
`to 1:58
`
`p.m., before Lisa C. Hundt, CSR, RPR, CLR in and for the
`State of Texas,
`reported by machine shorthand, at the law
`
`offices of Haynes and Boone,
`
`located at 2505 North Plano
`
`Road, Suite 4000, Richardson, Texas,
`
`in accordance with
`
`the Federal Rules of Civil Procedure and the provisions
`
`stated on the record or attached hereto.
`
`
`
`SOUND DEPOSITION SERVICES, INC.
`(888)297-6863
`
`
`IVI LLC EXHIBIT 2016
`XILINX V. IVI LLC
`IPR Case 2013-00029
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CERTIFIED copv
`
`) >
`
`XILINX,
`
`INC.,
`
`VS.
`
`) CASE:
`
`IPR20l3-00029
`
`) Patent 5,632.545
`
`INTELLECTUAL VENTURES I
`
`LLC,
`
`Patent Owner.
`
`)
`
`)
`
`)
`
`‘A9r~)rv\-~k*v|r~):~k1lv*~k*~Ir*~k~k~)r~)r*~k-Jr~k******~Jr********~k*-k~k**k*****~k**ir~k**~k
`
`
`
`ORAL AND VIDEOTAPED DEPOSITION OF
`
`A. BRUCE BUCKMAN
`
`Owner, and duly sworn, was taken in the above—styled and
`
`numbered cause on October 8, 2013,
`
`from 9:13 a.m.
`
`to 1:58
`
`p.m., before Lisa C. Hundt, CSR, RPR, CLR in and for the
`State of Texas,
`reported by machine shorthand, at the law
`
`offices of Haynes and Boone,
`
`located at 2505 North Plano
`
`Road, Suite 4000, Richardson, Texas,
`
`in accordance with
`
`the Federal Rules of Civil Procedure and the provisions
`
`stated on the record or attached hereto.
`
`
`
`SOUND DEPOSITION SERVICES, INC.
`(888)297-6863
`
`
`IVI LLC EXHIBIT 2016
`XILINX V. IVI LLC
`IPR Case 2013-00029
`
`
`
`
`
`
` A P
`
`P E A R A N C E S
`FOR THE PETITIONER:
`
`
`Mr. Thomas King
`
`HAYNES AND BOONE
`
`
`
`3
`
`
`
`
`18100 Von Karman
`Suite 750
`
`
`
`5
`
`Irvine, California 92612
`
`
`
`
`
`
`
`949.202.3059
`
`6
`
`949.202.33159 (Fax)
`
`Thomas.king@haynesboone.com
`
`
`
`
`
`7
`And
`
` Mr. Michael S. Parson
`
`HAYNES AND BOONE
`
`2505 N. Plano Road
`
`Suite 4000
`Richardson, Texas 75082
`
`
`
`10
`
`972.739.8611
`
`
`
`
`
`
`
`972.692.9003 (Fax)
`
`11
`
`michael.parson@haynesboone.com
`
`
`
`
`12
`
`13
`
`FOR THE PATENT OWNER:
`
`Mr. George E. Quillin
`And
`
`Mr. Paul Hunter
`
`FOLEY & LARDNER
`
`
`
`3000 K. Street, N.W.
`
`Suite 600
`
`Washington, DC 20007
`
`202.672.5413
`
`
`
`
`
`
`15
`
`16
`
`17
`
`
`
`
`
`
`
`
`
`
`ALSO PRESENT: Mr. Michael Barnes, Videographer
`
`
`
`SOUND DEPOSITION SERVICES, INC.
`(383) 297-6863
`
`202.672.5399 (Fax)
`
`gqui11in@fo1ey.com
`
`phunter@foley.com
`
`
`
`
`
`
`
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`2
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`4
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`Exhibits .
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`5
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`Stipulations .
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`DR. A. BRUCE BUCKMAN
`
`Examination by Mr. Quillin .
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`Examination by Mr. King .
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`5
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`49
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`57
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`Corrections Page .
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`59
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`
`
`SOUND DEPOSITION SERVICES, INC.
`(888)297-6863
`
`
`
`
`
`NO.
`
`DESCRIPTION
`
`PAGE
`
`2014
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`Liquid Crystals, Applications and Uses .
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`. .. 34
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`EXHIBITS
`
`PREVIOUSLY MARKED EXHIBITS
`
`1001 United States Patent 5,632,545, Kikinis
`
`1003 United States Patent 5,264,951, Takanashi
`
`1004 United States Patent 5,287,131, Lee
`
`1013 Reply Report of Dr. A. Bruce Buckman
`
`
`
`SOUND DEPOSITION SERVICES, INC.
`(888)297-6863
`
`
`
`
`
`P R O C E E D I N G S
`
`THE VIDEOGRAPHER:
`
`On the record at 9:13.
`
`Today is Tuesday, October 8th, 2013. This is the
`
`videotaped deposition of Dr. Bruce Buckman. This is
`
`beginning of Tape 1, Volume 1.
`
`Taken in the matter styled Xilinx versus
`
`Intellectual Ventures I, LLC, case IPR20l3—OOO29, Patent
`
`5,632,545 filed in the United States Patent and Trademark
`
`Office before the Patent Trial and Appeal Board.
`
`These procedures are being held at the
`
`offices of Haynes and Boone in Richardson, Texas. Will
`
`counsel please state their appearances and any agreements
`
`
`
`for the record.
`
`MR. KING:
`
`Tom King from Haynes and Boone
`
`here on behalf of petitioner Xilinx, and with me is Mike
`
`Parsons.
`
`MR. QUILLIN: George Quillin with
`
`Lardner, LLP, and with me is Paul Hunter, my
`
`at Foley & Lardner.
`
`THE VIDEOGRAPHER: Will
`
`the court reporter
`
`please swear in the witness.
`
`BRUCE BUCKMAN,
`
`having been first duly sworn,
`
`testified as follows:
`
`EXAMINATION
`
`
`
`BY MR. QUILLIN:
`
`SOUND DEPOSITION SERVICES, INC.
`(888)297-6863
`
`
`
`
`
`5
`
`A.
`
`My name is Alvin Bruce Buckman.
`
`I go by my
`
`middle name, Bruce.
`
`Good morning, Dr. Buckman.
`
`Good morning, Mr. Quillin.
`
` Would you please state your name for the
`
`
`Q.
`
`for today's deposition?
`
`
`
`9
`
`10
`
`11
`
`12
`
`A.
`
`All my declarations, all of Mr. Smith
`
`Gillespie's declarations, my depositions, Mr. Smith
`
`Gillespie's depositions, your motion to disallow,
`
`suppress my evidence,
`
`I'm not sure how that's titled, but
`
`15
`
`those patents.
`
`I believe that covers it.
`
`And what documents did you review to prepare
`
`
`
`
`
`
`
`The patents
`those —— those two motions that you made.
`
`themselves,
`the documents we're using as prior art for
`
`About how much time did you spend preparing for
` Q.
`
`today's deposition?
`
`18
`
`A.
`
`About eight or nine hours total.
`
`
` 19
`Q.
`I'm handing you what's been previously marked
`as Xilinx's Exhibit 1004. U.S. Patent Number 5,283,131
`
`
`
`
`
`
` to Lee.
`
`You're familiar with this patent, right?
`
`
`
`Q.
`
`
`
`23
`
`Yes. A.
`I want to ask you some questions about Item 19
`Do you believe that Item 19 of Lee is a video
`
`of Lee.
`
` 24
`
`controller?
`
`SOUND DEPOSITION SERVICES, INC.
`(888) 297-6863
`
`
`
`
`
`
`
`
`
`
`
`Let me read the spec here for a moment.
`
`(Witness reviewed document.)
`
`3
`
`A.
`
`No,
`
`I do not.
`
` Q.
`
`
`(BY MR. QUILLIN)
`
`So you believe that Item 19
`
`of Lee is not a video controller;
`
`is that correct?
`
` A.
`
`That's correct.
`
`Why is Item 19 of Lee not a video controller?
`Q.
`7
`
`
`Item 19 is not a video controller.
`It is
`
`A.
`
`8
`
`
`
`
`instead a controller for a light shutter.
`
`It's not a
`
`Video controller.
`
`video controller?
`
`
`
`13
`
`A.
`
`At one time I misidentified the box which was
`
`the video controller in —— in the Lee patent as
`
`Number 19.
`
`I corrected that subsequently in a later
`
`
`
`17
`
`
`18
`
`deposition.
`
`
`When you say you "misidentified the box," are
`
`Q.
`
`you saying that there was a time when you believed
`
`Item 19 was a video controller?
`
`20
`
`A.
`
`I made a mistake in identifying which box or
`
`
`
`boxes were the video controller in Lee. And I
`
`subsequently corrected it.
`And I apologize in advance for all the
`
`
`
`SOUND DEPOSITION SERVICES, lNC.
`(888)29T6863
`
`
`
`11
`
`Q.
`
`Have you ever believed that Item 19 of Lee is
`
`
`
`Q. Well, unpack for me the misidentifying.
`
`How
`
`did that come about?
`
`MR. KING:
`
`I'm going to object to this as
`
`beyond the scope of today's deposition.
`
`A.
`
`To the best I can recall how it came about, it
`
`was simply an honest mistake.
`
`Q.
`
`(BY MR. QUILLIN)
`
`A mistake in believing that
`
`Item 19 was a video controller when it was not;
`
`is that
`
`what you're saying?
`
`A.
`
`A mistake in identifying Box 19 rather than
`
`some other box or boxes as a video controller.
`
`Q.
`
`So how did it come about that it was Box 19
`
`that was the one that was identified as the video
`
`controller?
`
`A.
`
`It was a mistake.
`
`I can't recall really how it
`
`came about.
`
`It was a result of a conclusion that I
`
`erroneously came to and corrected on a further review of
`
`the patent.
`
`Q.
`
`But until that further review, you believed
`
`that 19 was a video controller;
`
`is that right?
`
`A.
`
`That was my original take on the specification
`
`and the figure.
`
`It turned out not to be correct.
`
`I
`
`discovered that and corrected it.
`
`Q.
`
`A.
`
`When did that original take occur?
`
`I don't recall when that original take
`
`SOUND DEPOSITION SERVICES, INC.
`(888) 297-6863
`
`10
`
`11
`
`12
`
`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
`
`23
`
`24
`
`25
`
`
`
`
` 1
`It would have been before the original
`occurred.
`
`
`declaration that I made, which misidentified the video
`
`
`
`4
`Q.
`
`And was it your own idea that Box 19 was a
`
`Video controller?
`
`controller as Box 19.
`
` A. Yes.
`
`
`
`7
`
`Q.
`
`So you looked at the Lee patent and it was your
`
`
`
`8
`
`idea that Item 19 was the video controller;
`
`is that
`
`
`
`right?
`
`
`
`10
`
`Yes. As
`
`A.
`
`Q.
`
`I just stated, it was my own idea. 11
`And you formed that idea sometime before you
`
`signed your first declaration in this —— in this
`
`is that right?
`That would have been the case because I put it
`
`proceeding;
`
`14
`
`A.
`
`into the first declaration.
`
`16
`
`Q.
`
`How long did you hold to that idea,
`
`that
`
`Item 19 was a video controller?
`
`
`
`I don't recall the amount of elapsed time
`18
`A.
`
`between originally misconcluding that 19 was a video
`
`
`
`controller and when the further review took place.
`
`don't recall the timing.
`
`
`
`I
`
`
`
`22
`
`Q.
`
`When did it happen that you changed your idea
`
`about Item 19 of Lee?
`
` 24
`A.
`As I just stated,
`
`25
`Q.
`Do you recall about when?
`
`
`I do not recall the timing.
`
`SOUND DEPOSITION SERVICES, INC.
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`
`
`
`A.
`
`Q.
`
`I can't even recall for you about when.
`
`Is it a common occurrence,
`
`in your experience,
`
`to have this sort of misidontification about an item in
`
`the prior art reference?
`
`A.
`
`No.
`
`Q.
`
`What did you do when you came to change your
`
`idea about Item 19?
`
`A.
`
`I corrected it at what I believe was the next
`
`available opportunity, which was my deposition, my next
`
`deposition.
`
`Q.
`
`Before the deposition, did you communicate your
`
`changed idea to anyone?
`
`
`
`MR. KING:
`
`I'll object to that,
`
`to the
`
`extent it calls for communications with counsel for
`
`Xilinx; and to the extent it does,
`
`I instruct the witness
`
`not to answer it.
`
`A.
`
`I'm going to follow the instructions of my
`
`attorney.
`
`Q.
`
`(BY MR. QUILLIN) What was it that caused you
`
`to change your idea about Item 19 of Lee?
`
`A.
`
`Q.
`
`A further review of the Lee patent.
`
`Until the time that you changed your idea, was
`
`it difficult to hold to that belief about Item 19 of Lee?
`
`MR. KING: Objection;
`
`lacks foundation.
`
`Until
`
`I reviewed the patent further and came
`
`10
`
`SOUND DEPOSITION SERVICES, INC.
`(888)297-6863
`
`
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`
`
`
`
`upon —— it wasn't new information, but redigested the
`
`information in the patent, before that time, no, it
`
`wasn't difficult to hold to my original conclusion.
`
` Q.
`
`(BY MR. QUILLIN) Until the time that you
`
`changed your idea about Item 19 of Lee, were there any
`
`
`
`naysayers?
`
`7
`
`MR. KING:
`
`I'll object to that again as
`
`seeming to call for communications with counsel and
`
`
`
`instruct the witness not to answer.
`
`I'll follow the instructions of my attorney.
`
`10
`A.
`
`
`(BY MR. QUILLIN) Apart from communications
`
`Q.
`
`with counsel, were there any naysayers?
`
`13
`
`A.
`
`I don't recall any other naysayers.
`
`Q.
`No one disagreed with you?
`
`15
`
`MR. KING:
`
`Same objection then, Counsel.
`
`I don't recall who may have disagreed with me.
`
`
`
`
`
`(BY MR. QUILLIN)
`
`Any self doubt about Item 19?
`
`18
`
`A.
`
`19
`
`than that. There's always the possibility that I can be
`
`
` Q.
`
`I approach conclusions in a more humble way
`
` wrong.
`
`
`
`I'm not perfect.
`
`21
`
`Q.
`
`How did you feel when you learned you were
`
`
`
`
`
`I mean,
`
`this has nothing to do with the patents at issue
`
`
`
`25
`in the case at this point. What are we doing here?
`
`
`11
`
`mistaken about Item 19?
`
` 23
`MR. KING: Objection. This is ridiculous.
`
`SOUND DEPOSITION SERVICES, INC.
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`
`
`
`
`
`
`
`A.
`
`In line with my general approach to all this,
`
`I
`
`said, okay,
`
`I made a mistake. Mistakes happen. And I
`
`took steps to correct it.
`
`Q.
`
`(BY MR. QUILLIN)
`
`As you know,
`
`this is the
`
`second deposition of yours in this case,
`
`in this IPR. At
`
`the time of your first deposition in this IPR, had you
`
`come to the change in your idea with Item 19 of Lee?
`
`A.
`
`All
`
`I
`
`remember about
`
`the timing is that I came
`
`to the conclusion that I'd mistakenly identified the
`
`controller,
`
`the video controller in Lee before I made the
`
`statements in —- whichever deposition it was where I
`
`corrected the identification. That's all I recall about
`
`the timing.
`
`Q.
`
`Before that deposition where you announced your
`
`change in that other case, you had seen the preliminary
`
`responses from Intellectual Ventures in this IPR and in
`
`the other IPR;
`
`is that right?
`
`A.
`
`I don't recall the exact
`
`timing of which
`
`documents came in when,
`
`I'm sorry.
`
`Q.
`
`So you don't recall those documents having an
`
`influence on —— on your changing your mind about Item 19?
`
`A.
`
`I don't recall when they came in,
`
`so I can't
`
`conclude anything about what
`
`the effect they had before I
`
`made the correction.
`
`
`
`
`
`MR. KING: Counsel,
`
`I'm going to object to
`12
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`SOUND DEPOSITION SERVICES, INC.
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`this whole line of questioning, once again, as beyond the
`
`
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`scope of today's deposition, which is the declarations
`
`that Mr. Buckman —- or that Dr. Buckman has recently
`
`submitted.
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`I don't know where this is going, but
`
`I know
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`that we're well past whatever —— we're well past
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`those
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`declarations at this point.
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`This is now the third deposition that
`
`Dr. Buckman's been cross~examined about Item 19, and we
`
`all know what the positions are and it's time to move on
`
`to today's testimony and not
`
`the testimony from several
`
`months ago.
`
`Q.
`
`(BY MR. QUILLIN) What do you understand about
`
`the extent of your duty to inform about changes in your
`
`position?
`
`MR. KING:
`
`Same objection.
`
`A.
`
`I don't have an understanding in terms of any
`
`legal requirements.
`
`I simply understand that if I make a
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`statement
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`in a declaration or a report that turns out to
`
`be incorrect,
`
`that I'm obligated to correct it as soon as
`
`I possibly can.
`
`Q.
`
`(BY MR. QUILLIN)
`
`And you believe you did that
`
`In this IPR?
`
`in this situation?
`
`A.
`
`I believe I did that in the deposition.
`
`believe that was the next opportunity.
`
`Q.
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`In this case?
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`To the best
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`I can recall, yes.
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`What do you now believe is the video controller
`
`
`
`A.
`
`I now believe the video controller in Lee
`
`consists of Boxes 20 and 21 in Figure 1.
`
`Q.
`
`And what does that video controller in Lee
`
`control?
`
`A.
`
`The video controller controls the spatial light
`
`modulators.
`
`Q.
`
`What figure do you believe illustrates that
`
`control?
`
`(Witness reviewed document.)
`
`Excuse me.
`
`I have to look at the specification
`
`(Witness reviewed document.)
`
`I think Figure 1 and Figure 2 both illustrate
`
`Q.
`
`(BY MR. QUILLIN)
`
`Lee doesn't use the words
`
`"spatial light modulator," does he?
`
`A.
`
`I'd have to do a word search to be sure, but
`
`it's possible that he doesn't.
`
`In Lee, it's the —— the
`
`large liquid crystal LC panel 11. That's basically the
`
`spatial light modulator in question here.
`
`Q.
`
`The elements 20 and 21 of Lee don't control
`
`
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`shutters l4R, 14G, 14B, do they?
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`Lee describes as controlling those shutters.
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`A.
`
`There's a shutter controlling circuit 19, which
`
`Q.
`
`My question's about elements 20 and 21 of Lee.
`
`Elements 20 and 21 of Lee don't control shutters 14R,
`
`14G, and 14B, do they?
`
`A.
`
`There's a link between them that is in this
`
`time multiplexing scheme with respect to color that Lee
`
`uses the pattern of —— of reflectivity.
`
`It would be --
`
`that's impressed on the LCD panel 11 must be timed to
`
`coincide with what's supposed to be reflected from red
`
`light. That pattern has to be impressed while the
`
`shutters are allowing red light to pass through, say,
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`the
`
`lens 12R.
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`The same thing would hold for the green and
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`the blue colors.
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`So there would have to at least be
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`synchronicity between the actions of shutter
`
`controller 19 and LCD controller 21 —— controllers 21 and
`
`20. And a link is shown in Figures 1 and 2.
`
`Q.
`
`You're saying that Item 19 controls the
`
`shutters 14R, 14G, and 14B;
`
`is that right?
`
`A.
`
`Item 19 is depicted in the specification as a
`
`light shutter control.
`
`Q.
`
`Let me hand you what's been previously marked
`
`as Xilinx's Exhibit 1013.
`
`(Witness reviewed document.)
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`Q.
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`(BY MR. QUILLIN) You've had an opportunity to
`
`
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`look through it. Does this look familiar to you?
`
`A.
`
`It certainly does.
`
`Q.
`
`A.
`
`Q.
`
`correct?
`
`A.
`
`Q.
`
`This is your reply report?
`
`That is correct.
`
`And you signed this just less than a month ago,
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`Correct.
`
`On page 4 of your reply declaration,
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`Exhibit 1013, paragraph 10, you say that you agree with
`
`the board's construction of a video controller adapted
`
`for controlling the light shutter matrices, right?
`
`A.
`
`Q.
`
`Right.
`
`Is a video decoder a component that facilitates
`
`the display of video?
`
`A.
`
`To the extent that a video controller is
`
`necessary in order to condition the signals,
`
`the
`
`electrical signals,
`
`in such a way that they can operate
`
`the display,
`
`the video decoder certainly assists in
`
`facilitating the display of video.
`
`Q.
`
`A.
`
`What is a video decoder?
`
`It would be a device that conditions the video
`
`signals such that they operate the video controller.
`
`Q.
`
`How do those conditioned signals operate the
`
`controller?
`
`M
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`A.
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`Sort of a circular definition.
`
`The condition
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`signals are the signals that are conditioned so as to
`
`operate whatever is downstream from that. That's what
`
`signal conditioning means.
`
`You have one device which
`
`expects a particular type of signal and signal
`
`conditioning comes upstream of that, produces the type of
`
`signals that the device expects.
`
`Q.
`
`Does Item 19 in Lee facilitate the display of
`
`video?
`
`(Witness reviewed document.)
`
`A.
`
`I
`
`think I would make this distinction about
`
`Item 19 and state that in Lee's particular scheme, it
`
`requires that the time in which the red,
`
`the green, and
`
`the blue light beams are impinging on the LCD panel,
`
`it —— that timing synchronicity I mentioned is required.
`
`To the extent that timing synchronism were
`
`to be broken,
`
`the -- the video would not display
`
`properly.
`
`So it has a —— it has a role to play, but so
`
`do the lamps 26 and we don't call them controllers.
`
`Q.
`
`(BY MR. QUILLIN) Are there components in a
`
`display system that facilitate the display of video yet
`
`do not meet your definition of a video controller?
`
`A.
`
`I believe I just gave you one example,
`
`the
`
`lamps 26 in Lee.
`
`Without
`
`them, you're not going to have
`
`a video display.
`
`No one of ordinary skill in the art
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`H
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`would call those part of any controller.
`
`Q.
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`A.
`
`Q.
`
`Same with Item 19 in Lee?
`
`I think Item 19 in Lee fits that category, yes.
`
`What
`
`type of signal triggers the video
`
`controller to operate or control the light shutter
`
`matrices?
`
`A.
`
`The type of signal would be the video signal as
`
`conditioned by whatever signal conditioning is between
`
`the raw video signal and the video controller.
`
`Q.
`
`In paragraph ll of your declaration,
`
`Exhibit 1013, about eight lines down in paragraph 11, you
`
`refer to, quote,
`
`these two functions, close quote.
`
`Do
`
`you see that?
`
`A.
`
`Q.
`
`Yes.
`
`You say that, quote,
`
`these two functions, close
`
`quote, are not performed in the same component. What
`
`two
`
`functions are you referring to?
`
`A.
`
`The decoding, which I'm calling the signal
`
`conditioning previous to the controller and then the
`
`actual —— the production of the actual control signals
`
`that go to the —— to the light shutter,
`
`the LCD ——
`
`shutter matrix, rather.
`
`Q.
`
`So what does the video signal have to do with
`
`the controlling of the light shutter matrix?
`
`A.
`
`The video signal, after it's been conditioned N
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`by what we're calling the video decoder, provides the
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`signals necessary to operate the video controller, and
`
`the signals which come out of the video controller go to
`
`
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`the light shutter matrix,
`
`the LCD.
`
`Q.
`
`What starts the controlling of the light
`
`shutter matrix?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`I'm sorry,
`
`I don't understand that question.
`
`How is the light shutter matrix controlled?
`
`You're referring to the light shutter matrix in
`
`Yes.
`
`It's controlled by signals which are sent to it
`
`from the video controller.
`
`They cause different
`
`locations in the shutter matrix to,
`
`in the case of the
`
`reflective LCD,
`
`like we see in Lee, different locations,
`
`different coordinates in this rectangular matrix X and Y,
`
`to be reflective or not be reflective, or perhaps be
`
`reflective at a level in between.
`
`Q.
`
`You mentioned before about synchronized and
`
`synchronization. Does the timing of the red, green, and
`
`blue need to be synchronized in Lee?
`
`A.
`
`Q.
`
`Synchronized with what? With respect to what?
`
`You mentioned a need for synchronization in
`
`
`
`Lee;
`
`is that right?
`
`A.
`
`Yes,
`
`I did.
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`light beams?
`
`Q.
`
`Is that relating to the red, green, and blue
`
`
`
`A.
`
`It's related to the timing of the red, green,
`
`and blue light beams, yes, it is.
`
`Q.
`
`If the timing of the red, green, and blue light
`
`beams needs to be synchronized, do the light sources need
`
`a consistent intensity during that time of
`
`synchronization?
`
`A.
`
`In an ideal well—operating system like this, it
`
`would be helpful if the light sources had a consistent
`
`intensity,
`
`if by "light sources" you're talking about the
`
`lamps 26 in Lee.
`
`Q.
`
`Yes. Are there other light sources you might
`
`have in mind in Lee?
`
`A.
`
`The lamps 26 are the only ultimate or first
`
`light sources that I see in Lee. As light propagates
`
`through the various elements in Lee, as in any other
`
`system like this, you can regard any other element of a
`
`source of light that's got certain characteristics.
`
`Q.
`
`Turning to page 13 of your declaration,
`
`Exhibit 1013, you say that the ‘S45 patent describes an
`
`electrically—addressed SLM, right?
`
`A.
`
`Q.
`
`Yes.
`
`And you also say that the SLM in Takanashi is
`
`
`
`an, quote, optically—addressed SLM, close quote;
`
`is that20
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`correct?
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`A.
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`Q.
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`That's correct.
`
`You don't point to anything in Takanashi
`
`to
`
`show the teaching of an optically—addressed SLM, do you?
`
`A.
`
`In paragraph 28,
`
`I make the statement that the
`
`optical addressing refers to the fact that write light
`
`controls the image encoded on the SLM,
`
`so I point to the
`
`write light in Takanashi.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Where is that?
`
`Paragraph 28?
`
`Yes.
`
`One,
`
`two,
`
`three,
`
`four lines down from the top
`
`of paragraph 28.
`
`Q.
`
`Why do you point
`
`to the textbook in
`
`paragraph 28?
`
`A.
`
`I point to it because it has a discussion of
`
`both types of spatial light modulator technology,
`
`the
`
`optically—addressed and the electrically—addressed.
`
`Q.
`
`Do all, quote, write lights used in the —— such
`
`systems mean that there's an optically—addressed SLM?
`
`A.
`
`I'm unaware of —— your question is very
`
`general.
`
`It covers all.
`
`I'm unaware of any systems that
`
`use write light as described in Takanashi where the
`
`addressing of the SLM itself would not be optical.
`
`Q.
`
`Is it true that electrically—addressed SLMs and
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`optically—addressed SLMS are different?
`
`
`
`A.
`
`On the top level,
`
`they're different in how
`
`they're addressed.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`How are they different?
`
`In addition to how they're addressed?
`
`Yes.
`
`Their functions as —— in terms of what
`
`they do
`
`to —— what Takanashi calls the read light,
`
`that is the
`
`light that is going to be passed through them or
`
`reflected off of them, if they are reflective,
`
`those
`
`functions are similar.
`
`The way and the mechanism by which they
`
`are addressed, as I've already stated,
`
`is different.
`
`This requires a somewhat different physical structure
`
`between the —— the two of them in terms of the
`
`electrically operated one requires wires, essentially,
`
`in
`
`order to —— in order to produce a spatially varying
`
`transmissivity.
`
`And I'll stick with the word
`
`"transmissivity" here, although in the case of reflective
`
`modulators,
`
`I would mean reflectivity.
`
`MR. KING: We've been going a little over
`
`an hour.
`
`Is it a good breaking point?
`
`MR. QUILLIN: Yes. Now's a good time for
`
`a break.
`
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`10:17.
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`THE VIDEOGRAPHER: Off the record at
`
`(Break taken.)
`
`THE VIDEOGRAPHER:
`
`Back on the record at
`
`10:29.
`
`Q.
`
`(BY MR. QUILLIN) Dr. Buckman,
`
`let me hand you
`
`what's been previously marked as Xilinx Exhibit 1001.
`
`This is the Kikinis '545 patent.
`
`Is there any place in
`
`this '545 patent that describes the claimed device is an
`
`SLM?
`
`A.
`
`Kikinis doesn't use the acronym or the words
`
`SLM in spite of the fact that that's what he has.
`
`Q.
`
`Rather in column 1,
`
`lines 23 to 26, doesn't it
`
`describe an active matrix LCD array?
`
`A.
`
`23 to 26 refers to active matrix color LCDS and
`
`uses the acronym AMLCDS. Reading on —- no, stopping at
`
`26, it talks about active matrix color LCDs,
`
`thin film
`
`transistor LCDs.
`
`THE REPORTER: What was the word before
`
`"transistor"?
`
`THE WITNESS: Thin film transistor.
`
`THE REPORTER:
`
`Thank you.
`
`Q.
`
`(BY MR. QUILLIN) Turning back to Exhibit 1013,
`
`your declaration on page 14, you say that,
`
`electrically—addressed SLMs and optically—addressed SLM,23
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`quote, create images out of rows and columns, close
`
`
`
`quote.
`
`A.
`
`Give me that page again, please.
`
`It took me a
`
`second or two to grab the paper.
`
`Q.
`
`A.
`
`Q.
`
`Page 14, paragraph 29.
`
`Right, okay.
`
`And then you say that, "In either type of SLM,
`
`images are created by organizing the continuous liquid
`
`crystal layer into a pixilated matrix of rows and
`
`columns"
`
`[as read].
`
`Do you see that?
`
`I do.
`
`Does a cathode ray tube,
`
`a CRT, does that have
`
`A.
`
`Q.
`
`a liquid crystal layer?
`
`A.
`
`Q.
`
`Typically, no.
`
`Are you saying in your declaration that the
`
`liquid crystal layer is shaped into rows and columns?
`
`A.
`
`I don't see the word "shaping" anywhere in
`
`there.
`
`I didn't say shape.
`
`I would not use shape to
`
`characterize.
`
`Q.
`
`Are you saying that the liquid crystal layer --
`
`in your declaration, are you saying that the liquid
`
`crystal layer is organized into rows and columns?
`
`A.
`
`I am saying that it's organized into rows and
`
`columns, yes.
`
`24
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`Q.
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`If one were to take a microscope and look at
`
`the liquid crystal layer, would one see rows and columns?
`
`A.
`
`When the device is operating,
`
`if one took a --
`
`I guess a polarizing microscope, perhaps, and -— and look
`
`at
`
`the liquid crystal matrix, one could see, should be
`
`able to see,
`
`the organization of rows and columns that's
`
`created.
`
`Q.
`
`Is it your View that the rows and columns are
`
`visual instead of being physical?
`
`A.
`
`I can't buy your construction there of visual
`
`instead of being physical.
`
`They can be both visual and
`
`physical.
`
`Q.
`
`A.
`
`But it's not shaped?
`
`I never mentioned shaped in paragraph 29.
`
`That's your word, not mine.
`
`The —— the liquid crystal
`
`matrix is altered. That may not result in a change in
`
`shape, but its optical properties are altered in certain
`
`rows and columns of the matrix.
`
`Its physical properties,
`
`optical properties are a physical property.
`
`Its physical
`
`properties are different.
`
`Q.
`
`Turning back a couple of pages to page 12 of
`
`your declaration, Exhibit 1013, you mention Takanashi.
`
`Let me hand you that. Here's Exhibit 1003,
`
`
`
`
`
` 24
`U.S. Patent 5,264,951, Takanashi. Does Takanashi say
`
`that the write light organizes the liquid crystal
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`elements,
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`the SLM,
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`into an XY matrix of pixels in rows
`
`
`
`and columns?
`
`A.
`
`I'm not going to word search through the whole
`
`Takanashi specification.
`
`To the best of my recollection,
`
`Takanashi does not mention by name rows and columns.
`
`However,
`
`somebody of ordinary skill in the art looking at
`
`Takanashi and looking at the title, which is a spatial
`
`light modulator system,
`
`somebody of ordinary skill in the
`
`art looking at Takanashi would conclude just from that
`
`title that the purpose of Takanashi's device is to create
`
`something which produces a spatially organized pattern of
`
`reflectivity or transmissivity based on the intensity of
`
`this write light at different points on the —— on the
`
`
`
`SLM.
`
`And so the write light is in this general
`
`picture an image, and the image has, due to fundamental
`
`optics and the wave nature of light,
`
`a limit on how much
`
`resolution it has, which means that over a very small
`
`distance, it's —— the intensity's incapable of -— of
`
`changing significantly. That's the resolution limit,
`
`the
`
`smallest possible spot size that you can ~- you can
`
`physically obtain.
`
`So if you think of your image as —— it can
`
`be thought of as a coordinate system,
`
`rows for going
`
`
`
`along the X axis, columns for going along the Y axis,
`
`the26
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`SOUND DEPOSITION SERVICES. INC.
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`
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`transmissivity or reflectivity of the SLM is organized
`
`
`
`into a matrix by the properties of the write light.
`
`
`
`And, again,
`
`to emphasize,
`
`somebody of
`
`ordinary skill in the art knowing that this patent is
`
`directed toward a spatial light modulator,
`
`looking at the
`
`figures alone, realizes that you're not going to get
`
`spatial light modulation unless you have some structure
`
`in the write light.
`
`It's not simply a single light beam
`
`bathing the whole spatial light modulator in constant
`
`intensity.
`
`Q.
`
`Paragraph 27 of your declaration, Exhibit 1013,
`
`starts off with your statement that Takanashi discloses
`
`several different ways to create an image using a liquid
`
`crystal device called a spatial light modulator SLM.
`
`What are those several different ways that Takanashi
`
`discloses to create an image?
`
`A.
`
`There are structures for the spatial light
`
`modulator and the various optical elements that surround
`
`it that get the light ready for spacial light modulation.
`
`And they vary things like the direction of the output of
`
`the read light with respect to the direction of the -- of
`
`the write light that's,
`
`for example, antiparallel in
`
`Figure 8, perpendicular in —— in Figure 11 —— I'm sorry,
`
`parallel in Figure 11. That's an example.
`
`
`
`And then the image creation means the ways
`27
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`SOUND DEPOS|T|ON SERVICES, INC.
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`to create an image that involves more than simply the
`
`
`
`spatial light modulator.
`
`In Figure 16, he describes an
`
`optical combiner is to combine light beams to produce
`
`color images in the read light. And there are other
`
`variations as well.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Any other ways in Takanashi?
`
`I'm sorry?
`
`Any other ways that Takanashi describes?
`
`No.
`
`Those are —— those are several ways to
`
`create the image.
`
`I don't know if I've recounted each
`
`and every one of them.
`
`Q.
`
`Paragraph 32 of your declaration, Exhibit 1013,
`
`starting at line 4,
`
`the sentence beginning "as explained
`
`
`
`above."
`
`Do you see that?
`
`A.
`
`Yes,
`
`I see the sentence.
`
`Do you want me to
`
`Yes, would you please read that?
`
`A.
`
`"As explained above,
`
`in Takanashi,
`
`the write
`
`light
`
`(which is usually from a CRT) organizes the liquid
`
`crystal elements in the Takanashi SLM into an XY matrix
`
`of pixels organized into rows and columns"
`
`[as read].
`
`Q.
`
`Thank you.
`
`Where does Takanashi describe that the
`
`write light is usually in the form of a CRT?
`
`
`
`A.
`
`That's not effectively what I'm saying here.
`
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`The explanation is in Takanashi for how the write light
`
`
`
`organizes the liquid crystal elements into rows and
`
`columns, et cetera.
`
`The write light coming usually from
`
`an SR —— from a CRT, excuse me.
`
`I'm —— I'm simply
`
`identifying a —- a way in which the write light can be
`
`delivered, and I'm using, as an example of that,
`
`the
`
`explanation above, which refers to the system pictured on
`
`page 16.
`
`Q.
`
`So it's correct that Takanashi does not
`
`describe a write light in the form of a CRT?
`
`A.
`
`As
`
`I explained,
`
`I think,
`
`in an earlier
`
`deposition as well, Takanashi is somewhat terse about his
`
`description of the write light. However,
`
`somebody of
`
`ordinary skill in the art, knowing that this is a spatial
`
`light modulator system that Takanashi is —— is claiming
`
`as his invention here, understands that the write light
`
`has to have a spatial distribution associated with it,
`
`such as an image.
`
`And one way to generate that image,
`
`somebody of ordinary skill in the art would also realize,
`
`is a CRT.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Takanashi doesn't say it's a CRT?
`
`As
`
`I just stated, no, he doesn't.
`
`On page 15 of your declaration, Exhibit 1013 --
`
`Okay.
`
`—— at the paragraph 30,
`
`the top of the page,
`
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