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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`)
`
`65, 70, 72, 73, 89
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`
`XILINX, INC.,
`Pefitioner,
`
`)
`)
`)
`|PR2013-00112
`)CASE:
`VS.
`) Patent 5,779,334
`INTELLECTUAL VENTURES |
`)
`)
`LLC,
`)
`)
`Patent Owner.
`anon-on».....nnnn.-mnmnmsmn.mcm
`ORAL AND VIDEOTAPED DEPOSITION OF
`A. BRUCE BUCKMAN
`NOVEMBER 12, 2013
`oneececeeeeiiMono-“non'nn-e-oeoeooe-toeen‘e-m
`
`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 November 12. 2013, from 1123 am. to
`5:38 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 own Procedure and
`the provislons stated on the record or attached hereto.
`
`A P P E A R A N C E S
`FOR THE PETITIONER:
`Mr. Thomas King
`HAYNES AND BOONE
`18100 Von Kantian
`Suite 750
`Irvine, California 92612
`949.202.3059
`94920233159 (Fax)
`thomas.king@haynesboonc.com
`And
`Mr. Michael St Parson
`HAYNES AND BOONE
`2505 N. Plano Road
`Suite 4000
`Richardson, Texas 75082
`972.739.8611
`97269219003 (Fax)
`nichaelparson®haynesboonecom
`FOR THE PATENT OWNEt
`Mr. George E Quillin
`And
`Mr. Paul Hunter
`FOLEY & LARDNER
`3000 K Street, NW.
`Suite 600
`Washington DC 20007
`202.672.5413
`2026725399 (Fax)
`gquillin@foley.com
`phunter@foley.com
`
`ALSO PRESENT: Mr. Don Coulman, Intellectual Ventures
`Mr. Michael Barnes, Videographer
`
`1
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`(Pages 1
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`to 4)
`
`I
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`Page 3
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`INDEX
`
`PAGE
`
`Appearances.......................................... 2
`Exhibits............................................. 4
`
`Stipulations......................................... 5
`BRUCEBUCKMAN
`
`Examination by Mr. Quillin......
`Examination by Mr. King.........
`Examination by Mr. Hunter....................
`Corrections Page.................................
`104
`Reporter‘s Certificate........................... 106
`
`mdmmwaH
`
`RD
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`Page 4
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`EXHIBITS
`PAGE
`NO. DESCRIPTION
`2016 Reply Report ofDr. A Bruce Buckman.......... 45
`2017 Declaration of A. Bruce Buckman, PhD. Under
`37 C.F.R Section 168 Directed to the
`Proposed Substitute Claims.................... 72
`
`PREVIOUSLY MARKED EXHIBITS
`1001 United States Patent 5,632,545............ 10, 20
`1002 US. Patent Number 5,264,951 .............26, 62
`1003 United States Patent 5,264,951 ................34
`1010 United States Patent 5,136,397............77, 94
`1011 Declaration ofA Bruce Buckman, PhD.
`Under 37 GER Section 1.68, Directed
`To the Proposed Substitute Claims........74, 75, 77,
`78, 80, 82, 88
`
`1012 Declaration of A Bruce Buckman, PhD.
`Under 37 CPR Section 1.68 Directed
`To Petitioner’s Reply.....................6, 16, 26,
`33, 38, 51,
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`V
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`SOUND DEPOSITION SERVICES, INC.
`(888) 297-6863
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`

`

`12 (Pages 45 to 48)
`
`Page 455
`(Exhibit Number 2016 was marked.)
`I want to hand you an exhibit from the other
`
`Q.
`
`
`
`
`‘
`
`IPR, IPR 2013-00029, and that [PR that had been
`previously marked as Exhibit 1013. We're going to give
`it a new number in this IPR and we're going to call it
`Exhibit 2016. This is your declaration signed on
`September of 20 1 3.
`Have you had a chance to look through that
`
`exhibit?
`
`A. You want me to read through it?
`
`I
`Q. What I'd like you to focus on is page 19,
`paragraph 35, where you say that Circuit 20 in Lee is an -
`example ofa video controller. Do you see that?
`A Right.
`Q. Why are the video controllers in Lee different
`for the '545 patent and the '334 patent?
`A I didn‘t say in either sentence ofthe
`declaration that either Circuit 20 by itselfor
`Circuit 20 and 21 constitute the one and only depiction
`of a video controller. What I said in both declarations
`
`was Circuit 20 is one example of a video controller.
`Circuits 20 and 21 are also one example ofa video
`controller. Those are examples. 1 did not state that
`either instance was the one and only one way to look at
`a video controller. If I have to pick one as the best
`
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`Page 47
`
`multiplexing in time and multiplexing in space as some
`of the other prior art references do. And someone of
`ordinary skill in the an would recognize the
`interchangeability of those ideas.
`Q. Where does Lee teach that configuration?
`A. Which configuration?
`Q. Being configured to control the light panels
`in relation to the beamed light?
`A Can you rephrase?
`Q. Sure. How are Elements 20 and 21 configured
`to control the LC panel?
`A.
`In terms of signal paths, they‘re configured
`as shown in Figures 1 and 2. That is, signals were sent
`from the video controller to the panel.
`Q. Anyplace else that Lee speaks to the control
`of the LC panel?
`(Witness reviewed document.)
`A. Describes the result of a process, column 3,
`line 59, "As a result the light beams of the colors red,
`green, and blue are successively reflected from the
`reflection type LC panel 11, according to the color
`driving signal" [as read].
`Ithinkl mentioned earlier in another
`
`deposition or in another declaration that there needed
`to be synchronicity between the -— the color hitting the
`
`Page 48
`
`LC panel and the signal that was - was going to the LC
`panel. This is characteristic, someone of ordinary
`skill in the art would recognize, of any system where
`you're going to time multiplex the colors as opposed to
`having all the colors present all the time.
`
`(BY MR QUILLIN) Would a person of ordinary
`Q.
`skill in the art understand the term "successive" to
`
`mean sequential?
`A Yes.
`
`Is Item 22 of Lee part of the video
`Q.
`controller?
`
`It's a frame-inducing circuit. It induces the
`A.
`respective light shutter. It induces —- the
`terminology, the respective light shutter and the image
`controlling circuit. Its connection with the image
`controlling circuit would be just to ensure this
`synchronicity.
`Q. Are there features of LC Panel 1 1 that make it
`a matrix?
`
`A LC Panel 11 is an electrically addressed LCD.
`
`And in an electrically addressed LCD, there is that bit
`of addressing is done in matrix fashion as it is with
`' optical.
`Q. And what is it about those features that make
`LC Panel 11 a matrix?
`
`
`
`Page 46l
`orthe optimal, I'll stickwiththe answer1 gave you
`i
`in, I believe, my last deposition, where I said it was
`i
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`20 and 21. But which answer you give depends on what i
`functions you put inside the controller, as we have been i
`talking about at some length today.
`i
`Q. What light shutter matrix system do
`!
`Elements 20 and 21 of Lee control?
`
`A. Elements 20 and 21 of Lee control Number 11 in E
`Figures 1 and 2.
`Q. And how many ofthose LC panels do these
`Elements 20 and 21 control?
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`A. They control a single light shutter matrix
`
`system, which adds in Lee's time multiplexing scheme of
`producing color as 3, but it acts as 3 at separate times
`during its operation because ofthe time multiplexing
`that I described to you earlier that is efiected by the
`color wheel and its rotation.
`
`Q. So how many single colored beams of light are
`efiected by the single LC panel of Lee?
`A One at a time and three in succession.
`Q. So in the system of Lee, elements of 20 and 21
`are not configured to control the same number of LC
`panels as beams of light; is that correct?
`A There‘s one LC panel. It acts separated over
`time on three beams of light. That‘s a choice between
`
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`
`XLNX-1023
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`

`

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` Page 105%
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`1
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`I, A. BRUCE BUCKMAN, have read the foregoing
`deposition and hereby affix my signature that same is
`true and 9°”th except “5 n°t°d ab°V°~
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`A. BRUCE BUCKMAN
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`THE STATE OF
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`1 0 COUNTY OF
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`Before me,
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`this day personally appeared AI BRUCE BUCKMAN, lcnown to i
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`l 4 me (or proved to me under oath or through
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`) (description of identity
`{
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`card or other document» to be the person whose name is
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`subscribed to the foregoing instrument and acknowledged
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`to me that they executed the same for the purposes and
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`consideration therein expressed
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`2 0
`Given under my hand and seal ofoflice this
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`day of
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`23
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`27 (Pages 105 to 107)
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`Page 107
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`I fitrther certify that I am neither attorney
`nor counsel for, nor related to or employed by, any of
`the parties to the action in which this deposition is
`taken, and further, that I am not a relative or employee
`
`of any attorney or counsel employed by the parties
`hereto, or financially interested in the action.
`.
`.
`I further certify that before the completion ofthe
`the
`deposition, _____X___ the Deponent, and/or
`did not request
`Plaintiff/Defendant, __X_ did
`‘
`to review the transcript.
`In witness whereof, I have hereunto set my hand and
`affixed my seal this
`day of
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`AD 2013.
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`LISA C. HUNDT, CSK RPR, CLR
`Texas CSR No. 6533
`Expiration Date: 12/31/14
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`COMMISSION EXPIRES:
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`NOTARY PUBLICINANDFOR
`THE STATE OF
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`Page 106‘
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`STATE OF TEXAS )
`COUNTY OF DALLAS )
`I, LISA C. HUNDT, a Certified Shorthand Reporter in
`and for the State ofTexas, hereby certify that,
`pursuant to the agreement hereinbefore set forth, there
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`came before me on the 12th day ofNovember, AD, 2013,
`at 11:23 am, at the office ofHaynes and Boone,
`located at 2505 North Plano Road, Suite 4000, in the
`City ofRichardson, State ofTexas, the following named
`person, to-wit: A. Bruce Buckman, who was by me duly
`cautioned and sworn to testify to the truth, the whole
`truth, and nothing but the truth ofhis knowledge
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`touching and conceming the matters in controversy in
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`this cause; and that he was thereupon carefully examined
`upon his oath and his examination reduced to writing
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`under my supervision; that the deposition is a true
`record ofthe testimony given by the witness, same to be
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`sworn and subscribed by said witness before any Notary
`Public, pursuant to the ageement ofthe parties; and
`that the amount of time used by each party at the
`deposition is as follows:
`Mr. Quillin - 3 hours, 49 minutes,
`Mr. King - 0 hours, 20 minutes,
`Mr. Hunter - 0 hours, 23 minutes,
`Mr. Parsons 0 hours, 0 minutes;
`
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`SOUND DEPOSITION SERVICES, INC.
`(888) 297-6863
`
`XLNX-1023
`
`XLNX-1023
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`