UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`)
`)
`)
`)
`) CASE: IPR2013-00112
`) Patent 5,779,334
`)
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`))
`
`))
`
`XILINX, INC.,
`
`Petitioner,
`
`VS.
`
`INTELLECTUAL VENTURES I
`LLC,
`
`Patent Owner.
`
`*********************************************************
`ORAL AND VIDEOTAPED DEPOSITION OF
`A. BRUCE BUCKMAN
`AUGUST 7, 2013
`*********************************************************
`
`ORAL AND VIDEOTAPED DEPOSITION OF A. BRUCE BUCKMAN,
`produced as a witness at the instance of the Patent
`Owner, and duly sworn, was taken in the above-styled and
`numbered cause on August 7, 2013, from 9:41 a.m. to 12:46
`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.
`
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`IVI LLC Exhibit 2019
`XILINX V. IVI LLC
`IPR Case 2013-00029
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`)
`)
`)
`)
`) CASE: IPR2013-00112
`) Patent 5,779,334
`)
`
`))
`
`))
`
`XILINX, INC.,
`
`Petitioner,
`
`VS.
`
`INTELLECTUAL VENTURES I
`LLC,
`
`Patent Owner.
`
`*********************************************************
`ORAL AND VIDEOTAPED DEPOSITION OF
`A. BRUCE BUCKMAN
`AUGUST 7, 2013
`*********************************************************
`
`ORAL AND VIDEOTAPED DEPOSITION OF A. BRUCE BUCKMAN,
`produced as a witness at the instance of the Patent
`Owner, and duly sworn, was taken in the above-styled and
`numbered cause on August 7, 2013, from 9:41 a.m. to 12:46
`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.
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`IVI LLC Exhibit 2019
`XILINX V. IVI LLC
`IPR Case 2013-00029
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`Page 2
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`A P P E A R A N C E S
`FOR THE PETITIONER:
`Mr. David L. McCombs
`HAYNES AND BOONE
`2323 Victory Avenue
`Suite 700
`Dallas, Texas 75219
`214.651.5533
`972.692.9116 Fax)
`david.mccombs@haynesboone.com
`
`FOR THE PATENT OWNER:
`
`Mr. George E. Quillin
`FOLEY & LARDNER
`3000 K. Street, N.W.
`Suite 600
`Washington, DC 20007
`202.672.5413
`202.672.5399 (Fax)
`gquillin@foley.com
`
`ALSO PRESENT: Mr. Don Coulman, Intellectual Ventures
`Mr. Michael Barnes, Videographer
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`INDEX
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`Page 3
`
`PAGE
`Appearances.......................................... 2
`Exhibits............................................. 3
`Stipulations......................................... 4
`A. BRUCE BUCKMAN
`4
`Examination by Mr. Quillin....................
`Examination by Mr. McCombs.................... 58
`Reporter's Certificate............................
`
`PREVIOUSLY MARKED EXHIBITS
`DESCRIPTION
`NO.
`1001 U.S. Patent Number 5,779,334
`1002 U.S. Patent Number 5,264,951
`1003 U.S. Patent Number 5,287,131
`1009 Excerpts from Guided Wave Photonics
`
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`P R O C E E D I N G S
`THE VIDEOGRAPHER: On the record at 9:41.
`Today is Wednesday, August 7th, 2013. This is the
`videotaped deposition of Dr. Bruce Buckman. This is the
`beginning of Tape 1, Volume 1.
`Will counsel please state their
`appearances and any agreements for the record.
`MR. QUILLIN: I'm George Quillin with
`Foley & Lardner, LLP, representing patent owner,
`Intellectual Ventures. With me is Don Coulman, in-house
`counsel for the patent owner.
`MR. MCCOMBS: My name is David McCombs
`with Haynes and Boone, and I'm here for Xilinx, the
`petitioner.
`
`THE VIDEOGRAPHER: Any agreements?
`MR. QUILLIN: We'll handle it later.
`THE VIDEOGRAPHER: Will the court reporter
`please swear in the witness.
`BRUCE BUCKMAN, Ph.D.,
`having been first duly sworn, testified as follows:
`EXAMINATION
`
`BY MR. QUILLIN:
`Q.
`Good morning, Dr. Buckman.
`A.
`Good morning, Mr. Quillin.
`Q.
`Please state your name for the record.
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`My name is Alvin Bruce Buckman. I go by my
`A.
`middle name, Bruce.
`Q.
`You've been deposed before, so you understand
`that you're under oath and that your testimony is being
`video-recorded?
`A.
`I do.
`Q.
`Are you taking any medications that would
`interfere with your testifying today?
`A.
`I'm not aware of any of their capabilities to
`interfere with my testifying. I take a list of
`medications.
`Q.
`And -- and your cell phone's turned off?
`A.
`My cell phone is turned off, yes.
`Q.
`What did you do to prepare for today's
`deposition?
`A.
`I reviewed the documents of the case, the
`patent in suit, the -- the prior art patent documents, my
`declarations that I previously made for this patent, and
`the transcript of my last deposition.
`Q.
`Any other documents?
`A.
`I believe that covers it.
`Q.
`How much time did you spend preparing for
`today's deposition?
`A.
`I spent the afternoon with -- with David and a
`team here, but not all of that was preparing for this
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`deposition. We were working on some -- some other things
`as well. And in addition to that, I spent a couple of
`hours in the evening.
`Q.
`So --
`A.
`So a total --
`Q.
`Rough total?
`A.
`Total in preparing for the -- the deposition
`itself of maybe four hours altogether.
`Q.
`What's a pixel?
`A.
`A pixel is a piece of a larger image usually
`or -- let's be more general than image, let's instead say
`a pattern -- a piece of a pattern, which is discrete in
`nature.
`Is that sometimes a term used instead of the
`Q.
`term "picture element"?
`A.
`It has similarity to the term "picture
`element." Picture element doesn't connote to me the same
`idea of discreteness necessarily. An element of a
`picture could be a color in the picture or could be a
`number of other things. Picture element is a much more
`general idea than pixel.
`Q.
`Is there a physical thing that you think of
`when you think of a pixel?
`A.
`Any kind of physical thing? That's a very
`general question. Can you possibly be a little more
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`specific than that?
`Q.
`I'm -- I'm trying to understand, in the context
`of the technology that's involved here, what a person of
`skill in the art would understand a -- a pixel to mean?
`A.
`A personal of ordinary skill in the art would
`understand a pixel to be a part of a pattern; and within
`that pixel or part of a pattern, there's negligible or no
`variation of the physical parameter in question that
`makes up the pattern.
`Q.
`Does a pixel exist apart from a pattern?
`A.
`I suppose that, in general, you could look at a
`pixel had been extracted from some image or some pattern
`and say, for example, in some sort of pattern or array,
`this pixel has certain characteristics, such as maybe in
`this pixel the underlying device is on or off; that is, a
`pixel carries with it a characteristic such as on or off.
`That's an example.
`Q.
`How does a pixel work?
`A.
`A pixel doesn't really need to work. A pixel
`is part of a -- is part of a pattern. An assemblage of
`pixels can be perceived either -- if we're talking about
`visual pixels and a picture which is perhaps the best
`example, okay, a -- a visual pixel is part of the overall
`picture. It has characteristics associated with it.
`Simple black and white kind of an image, it's either dark
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`or it's light. It may in some cases have varying levels
`of darkness or lightness. But whatever the pixel is,
`there are some parameters that one can use like light or
`dark to describe the condition of that pixel.
`And the way that -- to get back to your
`original question, the way a pixel works when a pixel is
`part of a pattern is to make up or to constitute that
`particular spatial part of the pattern over the extent of
`the pixel.
`Q.
`How many pixels are there in a VGA resolution
`display?
`I'd have to look that up. I don't know off the
`A.
`top of my head.
`Q.
`Big number, small number?
`A.
`Pretty big number.
`Q.
`Can you approximate it?
`A.
`Well, a typical picture that's on your computer
`screen, for instance, a picture that you look at on your
`computer screen might -- might be 1024-by-1024 just as --
`just as an example. So the entire picture might be made
`up of roughly a million pixels.
`But the -- that -- that number is elastic.
`It depends on the resolution of what's -- what's doing
`the image. You can have something that's high definition
`or something in your computer that makes up a -- a large
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`picture that contains a great many more pixels than that.
`Q.
`In such a display, like a VGA resolution
`display, are the pixels arranged know in an XY array to
`allow for forming of an image?
`A.
`They're -- they're typically arranged in an XY
`array that one would naturally describe using a Cartesian
`or rectangular coordinates system.
`Q.
`Multiple rows and multiple columns?
`A.
`Rows and columns or I like to think of it
`simply as spatial -- spatial coordinates with some
`granularity associated with them, describable in terms of
`a coordinate system, the most natural one being
`rectangular.
`Q.
`What about for liquid crystal displays in the
`mid-1990s, were the pixels arranged in an XY array to
`allow for forming of an image?
`A.
`In general with an electrically driven pixel --
`I'm sorry, an electrically driven display, the
`organization of electrical cells is in an array, which
`you can describe with a set of locations in XY Cartesian
`coordinates.
`Q.
`So was that a "yes" to my question? In a -- in
`a liquid crystal displays in the mid-1990s, were pixels
`displayed in an XY array to allow for forming an image?
`A.
`That answer's yes.
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`Okay. Let me hand you an exhibit. I've handed
`Q.
`you what's been previously marked as Xilinx's
`Exhibit 1001, which is U.S. Patent Number 5,779,334.
`You're familiar with this patent?
`A.
`Yes, I am.
`Q.
`Who is the inventor?
`A.
`The inventor is a Mr. Kikinis, if I'm
`pronouncing that correct.
`Q.
`And when was the patent application filed?
`A.
`The filing date listed is January 8, 1997.
`Q.
`Do you recognize this patent as a continuation
`in part of U.S. Patent 5,632,545?
`A.
`Yes. What I see here is a continuation in part
`of an application, which I'm assuming became '545.
`Q.
`Please turn to column 1 of the '334 patent.
`And near the top of that column, you'll see the heading
`"Field of the Invention." Under that heading, please
`read into the record the sentence about the field of the
`invention.
`A.
`In column 1, beginning at about line 7, the
`title of that paragraph is "Field of Invention," and the
`paragraph itself reads, "The present invention is in the
`area of video projection display and pertains more
`particularly to such displays using liquid crystal
`displays" [as read].
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`In the LCDs of the '334 patent, what role do
`Q.
`the pixels play?
`A.
`In the LCDs, the pixels play the role of the
`locations where the transmissivity or the transmission of
`the LCD display is set at the value that corresponds to
`the value for that color at that location, which one can
`measure with X and Y coordinates.
`So at a pixel, at that location and in the
`immediate neighborhood of that location, the
`transmissivity of a particular LCD is set to a value and
`that setting is done through external control -- control
`of the spatial light modulator of which the LC -- the LCD
`is a member of a class of devices called spatial light
`modulator.
`Q.
`Would a person of ordinary skill in the art in
`the mid-1990s understand the pixels of the '334 patent
`LCD to be arranged in an XY array to allow for forming of
`an image?
`Yes, a person of ordinary skill in the art
`A.
`would understand these pixels to be arranged in a
`rectangular array.
`Q.
`As of the filing date of the '334 patent, were
`pixels in a conventional LCD individually addressable?
`A.
`In order for the LCD to play this role we've
`talked about is a spatial light modulator, one has to be
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`able to, if one is going to display any image or any --
`any pattern one wants to display, one has to be able to
`individually address the pixels.
`Q.
`Are the pixels of the LCDs of the '334 patent
`individually addressable?
`A.
`It's a spatial light modulator, so by some
`scheme, the individual pixels have to be individually
`assignable, which means addressable. When you -- when
`you say "address," what you're saying, in effect, in
`terms of instructions is, I want this pixel located at
`some coordinate X and Y to be transmissive or
`nontransmissive or on or off if it's a -- if it's a light
`modulator that works in reflection or some other way,
`the -- the assignment that one makes is setting a
`transmissivity of a pixel to the desired value.
`So in one way or another, if one's going
`to display completely general patterns or images, any --
`any image one can conceive of, which is something that
`a -- that an imaging system basically needs to do, you
`have to be able to, in some way, individually address
`positions in the pixel. And by "individually address,"
`what I mean is to -- to assign and get in -- within
`operation then a value of transmission that one wants.
`Q.
`In the context of video projector systems, what
`is an LCD cell?
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`An LCD cell is -- I interpret that as being
`A.
`a -- another way to describe pixels. It's a -- it's a
`part of the spatial light modulator that corresponds to a
`particular position on a two-dimensional surface that
`corresponds to, in the case of a color projector, the
`transmissivity at a particular color.
`Q.
`So is it fair to say that your view is that the
`term "cell" in this context is a synonym for pixel?
`A.
`It's like a pixel; that is, there are -- there
`are full color LCD arrays where within one particular
`area of the picture, the red, green, and blue
`transmissivities are -- at that same physical location
`are set to three different assigned values. And in that
`case, if the color operations that are done separately in
`the '334 patent are done all at once in the same -- in
`the same cell, in a colored spatial light modulator, then
`one might consider that within this one pixel or cell,
`the way I'm -- I'm using the word, I have the capability
`to set the transmissivity for red and green and blue, all
`three.
`So does the question make any sense, how -- how
`Q.
`is a pixel related to an LCD cell? Does that question
`make any sense?
`A.
`As stated, I'm sorry to say no.
`Q.
`Okay. Is a matrix addressable display a
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`display in which electrical signals are applied to
`individual pixels to place or encode information on the
`display?
`Could I hear it again, that question again?
`A.
`Could she read it back, or could you restate it?
`Q.
`Is a matrix addressable display a display in
`which electrical signals are applied to individual pixels
`to place or encode information on the display?
`A.
`I think I would reverse the two parts of that
`definition you gave me. I think that a -- a display in
`which one can electrically address the different
`locations, that is a matrix display. Matrix display
`may -- may be broader.
`Q.
`In a color display, do you believe the cell
`includes the three pixels, red, green, and blue?
`A.
`A display might be different from a spatial
`light modulator. That is the overall purpose of the '334
`patent and a lot of the other prior art we've looked at
`in this case is to finally produce a color image where
`they're at a particular location in the -- in the
`pattern. There's a particular value for the red, the
`green, and the blue light.
`That might be -- somebody of ordinary
`skill in the art would understand that that might be
`accomplished with a color spatial light modulator, a
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`single one, where the cells or the pixels were organized
`in such a way that you got actions on the red, the green,
`and the blue parts of the light that's incident on the --
`on the spatial light modulator to begin with.
`But when you state it more generally in
`terms of the -- the cells or pixels or individual parts
`of an image, there are -- one of skill in the art would
`recognize there are multiple ways to accomplish that.
`Q.
`Do you agree that as of the filing date of the
`'334 patent, a person of ordinary skill in the art would
`understand the term "matrix" to mean a rectangular
`arrangement of elements into rows and columns?
`A.
`A person of ordinary skill in the art would
`understand that the rectangular arrangement of rows and
`columns is a matrix. Matrix, in the understanding of
`somebody of ordinary skill in the art, it's also a
`mathematical term which can be more general than a
`rectangular arrangement of rows and columns.
`We have a construction made by the board
`here, which makes -- equates matrix with this rectangular
`arrangement. But your question was, I believe, if I
`interpreted it correctly, how would somebody of ordinary
`skill in the art understand matrix.
`Q.
`You mentioned the board's definition. Do you
`think the board got it wrong in defining matrix?
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`No. I'm not saying that the board got it
`A.
`wrong, but you asked me what somebody of ordinary skill
`in the art would understand. And anybody who studied
`linear algebra as part of an engineering education
`understands that the word "matrix" goes further than
`that. This is a -- this is a definition of matrix
`that's -- that the board made that is tied to a -- an
`arrangement in two-dimensional space.
`Q.
`Let me hand you another exhibit. I just handed
`you what's been previously marked as Xilinx's
`Exhibit 1002 U.S. Patent Number 5,264,951. The inventor
`is Takanashi. You're familiar with this patent?
`A.
`Yes, I am.
`Q.
`Do you believe that Takanashi uses the phrase
`"LCD array spatial light modulator"?
`A.
`I would have to do a word search with a
`computer to answer your question accurately. I can't do
`it from memory.
`Q.
`No, I -- would you like to take a moment to
`look through it and see if can you find it?
`A.
`To be honest, I don't trust my capability to do
`a visual word search in any length of time which you
`might call reasonable. If you want me to do it, I will
`be -- I'll be happy to do it. It may take a while.
`Q.
`Well, I'll represent to you that our side has
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`looked through it and we can't find that phrase anywhere
`in Takanashi.
`A.
`All right. I take your representation.
`Q.
`Do you believe that Takanashi uses the term
`"array"?
`Same answer. I would have to do a word search
`A.
`to give you a definitive answer. And it would take a
`long time to do it visually.
`Q.
`You don't remember doing such a search before
`you wrote your declaration?
`A.
`I may have. I don't remember whether I did or
`did not.
`So as we sit here today, you don't have a
`Q.
`recollection that Takanashi does have the term "array" in
`it?
`
`That's correct, I don't have a recollection.
`A.
`Are all spatial light modulators addressed in
`Q.
`the same fashion?
`A.
`No.
`Q.
`What are the differences?
`A.
`The differences -- not to get too detailed but
`to stick with classes of differences, I'll start with how
`they're driven, how -- how they're operated, what type of
`physical effect is made use of in order to cause it to do
`what all spatial light modulators do; that is, create a
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`particular pattern of transmissivity versus the
`coordinates X and Y.
`In -- in a broad classification scheme,
`it's possible to do that electrically with electrical
`signals, as we've already talked about a little bit this
`morning. It's also possible to do it optically with
`light that's not part of the image to be formed. But
`light, for example, of another wavelength, which is used
`to operate the spatial light modulator and to tell it
`what pattern of transmissivity versus X and Y to impose
`on the light that's going through it.
`Q.
`Other than electrically and optically
`addressable spatial light modulators, are there other
`categories?
`A.
`There are -- I'm aware of some acoustically
`driven spatial light modulators in the guided weight
`optics space, where an acoustic wave propagating across a
`material through which some light is coming causes a
`variation in the transmissivity. So electrical and
`optical are -- I characterize them as the main
`operational mechanisms, but they're not the only ones.
`Q.
`Is it correct that one difference between
`spatial light modulators that are optically addressed, as
`distinct from those that are electrically addressed, is
`that the optically addressed spatial light modulators do
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`not use a matrix?
`A.
`No, I don't believe that's true.
`Q.
`Why is that?
`A.
`Considering what a spatial light modulator is,
`a consideration of that to someone of ordinary skill in
`the art who wants to operate one and is perhaps trying to
`choose between optical addressing and electrical
`addressing for his or her particular application, to
`consider the types of modulators, that person also as to
`consider the driving mechanism of the modulator. The
`driving mechanism of a spatial light modulator, be it
`optical or be it electrical, is what produces the matrix
`nature of the transmissivity.
`Q.
`Is the spatial light modulator of Takanashi an
`electrically addressed one or an optically addressed one?
`A.
`Takanashi is optically addressed.
`Q.
`How does the write light -- W-R-I-T-E -- how
`does the write light of Takanashi function?
`A.
`The write light of Takanashi, insofar as
`Takanashi talks about it and he's very terse in talking
`about it, Takanashi -- the write light of Takanashi
`serves to change the local state of his spatial light
`modulator from transmissive to nontransmissive. It sets
`the value of the transmissivity at some location.
`Q.
`Is it your view that in Takanashi there are
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`individually addressable pixels?
`A.
`Effectively, yes.
`Q.
`So you believe in -- that in Takanashi a pixel
`at one XY coordinate could be addressed differently than
`a pixel at a different XY coordinate?
`A.
`Yes.
`Q.
`Do you believe that the write light in
`Takanashi creates a pixilated image?
`A.
`Practically speaking, yes.
`Q.
`What do you mean by "practically speaking"?
`A.
`I mean inevitably; I mean in a real device.
`Q.
`Are you aware of real devices that embody
`Takanashi?
`A.
`No. But I understand somebody of ordinary
`skill in the art would understand how Takanashi's device
`works. And in understanding how -- how it works, one has
`inevitably a -- we use the term pixilated, discretized,
`granular, whatever terminology you might want to use,
`that the -- that the distribution of write light over the
`surface, that's what creates the spatial light modulator
`effect, how the write light is distributed over the
`surface of this liquid crystal. How that driving light
`is distributed over the surface, that's a matrix.
`Q.
`A rectangular array of rows and columns?
`A.
`Because the write light has that same
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`distribution with respect to the X and the Y coordinate,
`one of ordinary skill in the art would understand that
`that produces a matrix, a rectangular arrangement.
`Q.
`Does the charge-generating photo-conducting
`layer of Takanashi interact with a single pixel or with
`all the pixels?
`A.
`The charge-generating layer is excited by the
`write light in order to change the electric field that
`the liquid crystal sees, and hence change the
`transmissivity. The excitation of that is local. It's
`associated with a particular value of X and Y, and that
`excitation depends on how the write light is spatially
`distributed with respect to X and Y.
`Q.
`Are the pixels of the display in Takanashi
`individually addressable?
`A.
`With the correct distribution of write light,
`
`yes.
`
`I evidently didn't understand your answer to
`Q.
`the question about the charge-generating photo-conducting
`layer of Takanashi and whether it interacts with a single
`pixel or with all of the pixels simultaneously.
`What's -- what's your understanding of that?
`A.
`Okay. In your earlier question, you didn't use
`the word "simultaneous" -- or simul -- "simultaneously."
`Simultaneously refers to, in my understanding, an
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`ordering in time.
`Q.
`Okay.
`A.
`In principle, one can address two or more
`different pixels or different elements of this
`rectangular matrix, if you will, at the same time
`simultaneously. That's -- can be the case with -- with
`write light in Takanashi correctly presented. That is,
`forming the write light, the W-R-I-T-E light in the
`right, R-I-G-H-T, way one can address two different
`pixels simultaneously.
`Q.
`Where does Takanashi teach that?
`A.
`Takanashi simply talks about using the write
`light to create this pattern in the liquid crystal, which
`in his patent functions as a spatial light modulator. So
`it is a spatial light modulator that's -- that's driven
`optically rather than electrically.
`Takanashi simply talks about the write
`light during this process of energizing the photo
`conductive layer in the crystals so as to create this
`pattern of transmissivity. If the device is to be a
`spatial light modulator, it has to effect the
`transmissivity differently at different values for X
`and Y.
`
`So that says to me, says to one of
`ordinary skill in the art, that regardless of how it
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`might be distributed over time, simultaneously or not,
`setting that aside, that at different positions,
`different values of X and Y, that the write light is
`different.
`Q.
`If you'd turn to Figure 17 of Takanashi.
`A.
`Okay.
`Q.
`What element or elements in Figure 17 of
`Takanashi represent the matrix?
`A.
`The matrix is created, as I've explained or
`tried to, by the write light at different positions
`within these liquid crystals. And the write light in
`Figure 17 of Takanashi is inconveniently not shown. I
`believe he states that it's not shown. But it's -- I
`think he also states that it's there. I'd have to look
`for that, but I do recall that kind of a statement about
`the write light in Figure 17.
`But if you look at Figure 17, you don't
`find any WL designations, which refer to the write light.
`Q.
`So is it correct that, in your view, Figure 17
`of Takanashi does -- does not illustrate an element or
`elements that represent a matrix?
`A.
`No. I think -- if you're speaking literally of
`Figure 17 and only Figure 17, and you draw boundaries
`around Figure 17 and talk in terms of what is there in
`Figure 17 and what is not, since there's no write light
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`depicted in Figure 17 -- although he says in the text
`that it's there -- since there's no write light depicted
`in Figure 17, since it's the write light that creates the
`matrix in this type of -- of liquid crystal spatial light
`modulator, the precise answer to your question is that
`the matrix nature of the light modulators is not depicted
`explicitly in Figure 17.
`Q.
`You say that the write light creates the
`matrix. So in the absence of the write light, there is
`no matrix; is that correct?
`A.
`In the absence of write light, just no write
`light impinging at all, that's the equivalent, in more
`generic terms, of a spatial light modulator built some
`other way, say electrically, that's not driven at all.
`So in terms of the transmissivity, it's
`constant at some value over the whole surface. A -- a
`matrix isn't really -- in optical terms -- put it that
`way. In optical terms, a matrix of transmissivity is not
`created until the spatial light modulator, however it's
`addressed, is actually driven. But all spatial light
`modulators to operate must be -- must be driven whether
`it's electrical, whether it's optical, or whether it's
`something else.
`Q.
`So is it correct that to condense that -- that
`answer to say that in Takanashi, in the absence of a
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`write light, that Takanashi does not have a matrix?
`A.
`Although it's technically correct to -- to make
`that statement and stop there, it's also important and
`somebody of ordinary skill in the art would certainly
`make this operation, that without the write light in
`Takanashi, you don't have any spatial light modulation at
`all, so you don't have Takanashi's device being operable.
`That is that -- that posit you make about turning off the
`write light effectively turns off the image or pattern
`processing capability of Takanashi's invention, just as
`turning off the drive totally in -- in an electrically
`driven modulator would -- spatial light modulator would
`do the same thing, that is it would render the overall
`system that this spatial light modulator is in. In the
`invention in question, it would render it inoperable.
`Q.
`So as you take this device of Takanashi out of
`the box, before you turn on a light to do anything,
`before you do that, take the device of Takanashi out of
`the box, there's no matrix; is that correct?
`A.
`If you take the device out of the box, there
`isn't a matrix; but if there isn't a matrix, Takanashi's
`device is inoperable just as any other device employing a
`spatial light modulator would be inoperable for the
`purposes of spatial light modulation if it were not
`driven.
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`It would be inoperable until you turned on the
`Q.
`light? Takanashi, you're saying, would be inoperable
`until you turned on the light?
`A.
`Until you turned on the write light, as well as
`the read light and otherwise powered up the system. And
`that situation would basically be the same in the case of
`an electrically driven light modulator. It would not be
`operable.
`It would not be operating, but I -- I want to
`Q.
`make sure I understand what you're saying. You go -- you
`know, you go to Radio Shack and you buy one of the
`Takanashi's devices, you bring it home, it's in a box.
`You take it out of the box and it's sitting on the table,
`you haven't plugged it in or turned on any lights, you're
`saying that in that condition, the device of Takanashi
`does not have a matrix?
`A.
`It doesn't have a matrix of transmissivity as a
`function of X and Y, which is -- the purpose of having a
`spatial light modulator of any kind is to create that
`distribution of transmissivity, that matrix of
`transmissivity versus X and Y. It can't create the
`matrix of transmissivity until you turn on the write
`light in the Takanashi device that you took out of the
`box.
`
`But if I took out of the box another
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`device, another -- another projector configured to do
`basically the same thing, it cannot create a matrix of
`transmissivity, transmissivity versus X and Y, that it
`needs in order to function unless I am turning on the
`driving mechanism for it.
`Q.
`So take, for example, the Kikinis '334 patent,
`it's Exhibit 1 -- Exhibit 1001.
`A.
`Right.
`Q.
`If you were to go to Radio Shack and get one of
`those devices, bring it home, take it out of its
`packaging box and put it on your table, before you did
`anything to it, would there be a matrix present in the
`device of Kikinis?
`A.
`There wouldn't be a spatial distribution of
`transmissivity that corresponds to what locations in the
`matrix of transmissivity get addressed and turned on or
`off until I turned on the drive to the spatial light
`modulators; and in this case, the electrical drive of the
`spatial light modulators.
`The key point here is let's not buy the
`whole device, let's take the spatial light modulating
`part of it out of the box and look at that. I'm never
`going to get a pattern, or a matrix of transmissivities,
`until I energize the device and apply some drive to it.
`There is no spatial in the spatial light modulator
`
`SOUND DE
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