SEL EXHIBIT NO. 2012
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`INNOLUX CORP. v. PATENT OF SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
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`IPR2013-00038
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`INNOLUX CORP. v. PATENT OF SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
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`IPR2013-00038
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`INNOLUX CORPORATION,
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` Petitioner,
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` vs. No. IPR2013-00038
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` Patent 7,956,978
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`PATENT OF SEMICONDUCTOR,
`
`ENERGY LABORATORY CO., LTD.,
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` Patent Owner.
`
`------------------------------------------------------
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` VIDEOTAPED DEPOSITION OF MILTIADIS HATALIS, Ph.D.
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` Irvine, California
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` Monday, May 20, 2013
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` Volume I
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`Reported by:
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`SHERRY A. CASE, RPR, CLR,
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`CSR No. 2989
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`Job No. 1665084
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`INNOLUX CORPORATION,
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` Petitioner,
`
` vs. No. IPR2013-00038
`
` Patent 7,956,978
`
`PATENT OF SEMICONDUCTOR,
`
`ENERGY LABORATORY CO., LTD.,
`
` Patent Owner.
`
`______________________________________________________
`
` Videotaped Deposition of MILTIADIS
`
`HATALIS, Ph.D., Volume I, taken on behalf of Patent
`
`Owner, 3 Park Plaza, Suite 1100, Irvine, California,
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`beginning at 7:36 a.m., and ending at 4:10 p.m. on
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`Monday, May 20, 2013, before SHERRY A. CASE, Certified
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`Shorthand Reporter No. 2989, CLR, RPR.
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`APPEARANCES:
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`FOR THE PETITIONER:
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`Page 3
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` JEFFER MANGELS BUTLER & MITCHELL LLP
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` BY: GREGORY S. CORDREY, ESQ.
`
` 3 Park Plaza
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` Suite 1100
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` Irvine, CA 92614
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` 949.623.7236
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` GCordrey@jmbm.com
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`FOR THE PATENT OWNER:
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` STEPTOE & JOHNSON LLP
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` BY: STANLEY A. SCHLITTER, ESQ.
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` DOUGLAS R. PETERSON, ESQ.
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` 115 South LaSalle Street
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` Suite 3100
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` Chicago, IL 60603
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` 312.577.1250
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` Sschlitter@steptoe.com
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` Dpeterson@steptoe.com
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`APPEARANCES (CONTINUED):
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`FOR THE PATENT OWNER:
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` ROBINSON INTELLECTUAL PROPERTY LAW OFFICE
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` BY: ERIC ROBINSON, ESQ.
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` 3975 Fair Ridge Drive
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` Suite T20 North
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` Fairfax, VA 22033
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` 571.434.6789
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` Erobinson@riplo.com
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`VIDEOGRAPHER: SCOTT SLATER
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` I N D E X
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` WITNESS: MILTIADIS HATALIS, Ph.D.
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` EXAMINATION
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` BY MR. SCHLITTER: 8
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` E X H I B I T S
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` EXHIBIT DESCRIPTION PAGE
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` Exhibit 1005 Declaration of Miltiadis 8
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` Hatalis, Ph.D.
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` Exhibit 1001 '978 Patent 15
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` Exhibit 1003 Patent 5513028 16
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` Exhibit 1004 Patent 5504601 165
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` Irvine, California; Monday, May 20, 2013:
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` 7:36 A.M.
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`Page 6
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` THE VIDEO OPERATOR: Good morning.
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` We are on the record at 7:36 a.m. on May 20th,
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` 2013. This is the video-recorded deposition of
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` Dr. Milt Hatalis.
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` My name is Scott Slater, here with our court
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` reporter, Sherry Case. We are here from Veritext
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` Legal Solutions at the request of counsel for the
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` patent owner.
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` This deposition is being held at 3 Park Plaza,
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` Suite 1100, in the City of Irvine, California 92614.
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` The caption of this case is Innolux Corporation versus
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` Patent of Semiconductor Energy Laboratory Co., Ltd.,
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` Case No. IPR 2013-00038, Patent 7956978.
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` Please note that audio and video recording will
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` take place unless all parties agree to go off the
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` record. The microphones are sensitive and may pick up
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` whispers, private conversations, or cellular
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` interference.
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` I'm not authorized to administer an oath. I'm
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` not related to any party in this action, nor am I
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` finan- -- nor am I financially interested in the
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` outcome in any way.
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` May I please have an agreement from all parties
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`Page 7
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` that we may proceed.
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` MR. SCHLITTER: You may proceed.
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` MR. CORDREY: That's fine.
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` THE VIDEO OPERATOR: Thank you.
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` At this time, will counsel and all present
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` please identify themselves for the record.
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` MR. SCHLITTER: Stan Schlitter for the patent
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` owner, and I'm with Steptoe & Johnson.
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` MR. CORDREY: Gregg Cordrey, from Jeffer,
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` Mangels, Butler & Mitchell, on behalf of the
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` petitioner, Innolux Corporation.
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` THE VIDEO OPERATOR: Thank you very much.
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` Will the court reporter please administer the
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` oath.
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` THE COURT REPORTER: Please raise your right
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` hand.
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` You do solemnly swear that the testimony you're
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` about to give in the cause now pending to be the
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` truth, the whole truth, and nothing but the truth.
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` THE WITNESS: I do.
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` THE COURT REPORTER: Thank you.
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` ///
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` ///
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` ///
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` MILTIADIS HATALIS, Ph.D.
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`Page 8
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` having been first administered an oath, was examined
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` and testified as follows:
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` EXAMINATION
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` BY MR. SCHLITTER:
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` Q Good morning, Dr. Hatalis.
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` A Good morning.
`
` Q I've handed you what has previously been marked
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` as Exhibit 1005.
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` (Exhibit 1005 was previously marked
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` for identification by the court
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` reporter and is attached hereto.)
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` BY MR. SCHLITTER:
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` Q Do you recognize this document?
`
` A Yes, I do.
`
` Q What is this document?
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` A It is my declaration and in regards to the
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` review of the U.S. Patent 9 -- No. 7956978.
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` Q Did you author this document?
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` A Correct.
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` Q Did you write every word that's in it?
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` A Every word in -- in it? No.
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` Q What did you do to prepare for your deposition
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` today?
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` A I review my declaration. I review the
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` petition. I review the board decision, the request
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` for rehearing, the decision of the board on the
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` request for rehearing, the '978 Patent, and the
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` relevant -- the patents that I use from the prior art,
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` namely, that one from Sono and Watanabe.
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` Q Did you meet with anyone to prepare for your
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` deposition?
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` A Yes.
`
` Q When was that?
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` A That was on Friday, two days ago, and about two
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` weeks ago.
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` Q And who did you meet with on both those
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` occasions, on each of those occasions?
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` A On Friday I met with --
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` MR. CORDREY: Saturday.
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` THE WITNESS: Sat- -- Saturday. Excuse me.
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` Saturday.
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` On Saturday, I met with Greg Cordrey and his
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` colleague, Stan --
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` MR. CORDREY: Gibson.
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` THE WITNESS: -- Gibson.
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` And about two weeks ago, I met with
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` Greg Cordrey and his colleague, Ali --
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` MR. CORDREY: Shalchi.
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` THE WITNESS: -- Shalchi.
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` BY MR. SCHLITTER:
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` Q Did you discuss the '978 Patent at both of
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` those meetings?
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` A Yes.
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` Q To be clear, the -- the meeting was Saturday.
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` Was there a meeting on Friday?
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` A No. Friday, it was -- I have misspoken.
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` Friday night I arrive here.
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` Q Were you shown any papers or documents at those
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` meetings?
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` A No.
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` We reviewed the -- the binders that are in this
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` room.
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` Q Do you mean the -- the items that you listed?
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` A Correct.
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` Q Did you do any searching of prior art in
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` connection with your work in preparing the declaration
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` that's Exhibit 1005?
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` A No.
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` I was provided with the references and I was
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` asked to give an opinion.
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` I've also had been provided with other
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` references, I may add, which I -- I found that may not
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` be necessarily as strong as the ones that I -- I use
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` in my declaration.
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` Q About how many other pieces of prior art were
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` you provided?
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` A I don't remember. It was probably a handful, a
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` few.
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` But, as I said, some of them, I didn't have to
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` look very deep into them.
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` Q Did you rely on any of the prior art other than
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` Sono and Watanabe?
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` A I relied on the APA which is disclosed in the
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` '978 Patent.
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` Q Other than the APA disclosed in the '978
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` Patent, Sono and Watanabe, did you rely on any other
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` prior art in connection with your declaration or work
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` in this case?
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` A No.
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` I relied on someone's ordinary skill in the art
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` at the time of the invention to refer judgment on
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` certain items related to the issues raised by the
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` claims.
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` Q And what did you base someone's ordinary skill
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` in the art at the time of the invention on?
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` A Well, I believe there is a section here which
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` is about like a college degree in a field like
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` electrical engineering or physics or related fields,
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` material science, and a few years of experience in the
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` field.
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` Q Are you the person who authored the part of the
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` declaration that talks about level of ordinary skill
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` in the art?
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` A I was provided with that legal -- or that
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` background information related to the former
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` requirements of the ordinary skill in the art.
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` Q You were provided that by counsel?
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` A By the counsel at --
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` Q Would that be Mr. McKeown?
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` A Scott McKeown was the leader of the -- I worked
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` with Scott McKeown, but I also worked with a couple
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` other attorneys at Upland.
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` Q Who else did you work with there?
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` A I believe Tom Fisher is one of the lawyers, and
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` I worked with one more. I forgot one of the
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` associates, and I don't remember the name right now.
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` Q Is the curriculum vitae attached as Appendix A
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` to the declaration identical to the curriculum vitae
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` that was attached to the declaration attached or used
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` with respect to the '480 Patent that we discussed in
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` the deposition yesterday?
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` A I believe so. If there had been some writings,
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` I don't remember, but I believe it's the same.
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` Q You believe it to be complete and accurate?
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` A As of the time of the writing of this
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` declaration, which was back in the 4 of 2012 (sic).
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` Q Is there any respect that you were aware of in
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` which it is not any longer complete or accurate?
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` A At the time of the writing or now?
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` Q Right now.
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` A Right now? There are some additional papers or
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` scientific journals, conferences that have not been
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` included, that were published since the writing of
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` this one, and there is some additional funding that I
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` received other than the one listed in this
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` Section 10A.
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` Q Did any of those papers relate to liquid
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` crystal displays?
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` A Those papers relate to transistors and active
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` metrics displays, and these are basic materials and
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` devices that are -- they're used in displays.
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` In recent years, I covered other type displays
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` as well.
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` Q Are all those publications identified on your
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` website?
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`Page 14
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` A I think my website is more outdated than this
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` document.
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` Q Is there anywhere where there is a list of the
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` recent publications that are not included on your CV?
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` A I can provide them to you if you require them.
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` MR. SCHLITTER: Mr. Cordrey, could you provide
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` that to us?
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` MR. CORDREY: Yes.
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` BY MR. SCHLITTER:
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` Q Do any of those publications relate to the
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` subject matter of the '978 Patent?
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` And I mean by "those publications" the recent
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` ones that have been published since your CV was
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` authored last fall.
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` A These publications are related to thin film
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` transistor technology and for a means of driving
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` active metrics, organic light-emitting diodes
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` displays. It relates to a pixel architecture and
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` circuitry within the pixel, and relates to means to
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` address those pixels.
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` MR. CORDREY: Just to clear the record, I said
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` we'll take that under advisement, yes.
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` MR. SCHLITTER: We'll take "yes."
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` MR. CORDREY: I'm sure it's not an issue, but I
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` want to make sure the record's clear.
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` THE WITNESS: Don't expect it to be too many.
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` MR. SCHLITTER: Thank you.
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` BY MR. SCHLITTER:
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` Q Would you refer please to Paragraph 38 of your
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` declaration.
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` Paragraph 38 states, "One skilled in the art
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` would recognize that the horizontal and vertical
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` scanning circuits, 72 and 73, of Sono's Figure 7 are
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` the same as the horizontal and vertical shift
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` registers, 5 and 6, Sono's Figure 4."
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` Let me add a little bit more.
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` Also in quotes, "A horizontal shift register,
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` 5; a vertical shift register, 6."
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` I've handed you what is marked as Exhibit 1001.
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` (Exhibit 1001 was previously marked
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` for identification by the court
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` Reporter and is attached hereto.)
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` BY MR. SCHLITTER:
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` Q Do you recognize this document?
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` A Yes.
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` Q What is this?
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` A This is the patent referred to as the '978
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` Patent that I analyzed in my declaration and compared
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` it with the prior art.
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` Q I also have handed you what is marked as
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
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` Exhibit 1003, which is U.S. Patent 5513028 to Sono, et
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`Page 16
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` al.
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` (Exhibit 1003 was previously marked
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` for identification by the court
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` reporter and is attached hereto.)
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` BY MR. SCHLITTER:
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` Q Do you recognize this document?
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` A Yes.
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` Q What is this?
`
` A This is the U.S. Patent which is referred in
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` the declaration as the Sono patent, and I used the
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` teachings and the information related to the invention
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` of Sono to express an opinion whether the alleged
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` innovations in the '978 Patent were known in the art
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` or someone with ordinary sill in the art would have
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` concluded that, in light of Sukegawa, the '978 would
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` have been obvious.
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` Q What is the basis for your statement in
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` Paragraph 38 that one skilled in the art would
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` recognize that the horizontal and vertical scanning
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` circuits, 72 and 73, of Sono's Figure 7 are the same
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` as the horizontal and vertical shift registers, 5 and
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` 6, of Sono's Figure 4?
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` A Well, shift registers is the displays that
`
` include integrated display drivers. A shift register
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` is the predominant circuit used to fabricate and
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` implement integrated display drivers. And in Figure 4
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` of Sono, in the block diagram, the Elements 5 and 6
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` are labeled as horizontal shift register and vertical
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` shift register. Those circuits perform the same
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` function as those disclosed in Figure 7, as well as
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` some of the other figures that are not referring to my
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` declaration, like 10 and 11.
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` One ordinarily skilled in the art would know
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` that shift registers are used. They are disclosed in
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` Figure 4, and they -- there would be no reason why
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` some other type of a circuitry different than a shift
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` register will be used in Figure 7 or any of the other
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` figures.
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` Furthermore, Sono is referring to fabricate the
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` same circuitry, the same components in a number of
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` different places in the specifications. It does not
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` refer anywhere that from one figure to a different
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` figure or from one circuit block within a figure to
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` another circuitry block within a figure there will be
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` changes in the type, layout, or design of those
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` circuitries.
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` Q What is the basis for your statement in
`
` Paragraph 38 that the dummy circuits, 74 and 75, will
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` also be dummy shift registers?
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` A As I said, in the specifications of Sono he
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` refers to the dummy circuits, 74 and 75, being
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` fabricated at the same time as the horizontal or
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` vertical scanning circuits, 72 and 73, that they have
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` the same step.
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` You can see from the Figure 7 that they have
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` the same extent in the -- in the sealing area, 76
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` mark. So they have the same physical dimensions, and
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` someone with ordinary skill in the art would know that
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` in order to achieve the same step, the same surface
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` to -- you -- it would be obvious to use the same
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` circuit. This will save -- this will not only
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` guarantee the same step height, but will also have
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` other advantages, such as you will not have to spend
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` design time in creating a different mask. It will use
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` the same fabrication processes as those used to
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` fabricate the other circuits.
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` So there are a number of reasons that these
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` circuits, 74 and 75, will be identical to 72 and 73.
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` Q You said that this is referenced in the
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` specification.
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` Where exactly in the specification are you
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` referring to?
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` A Okay. If we look at Column 5, Line 6, it
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` reads,
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` "A horizontal scanning circuit, 72, a
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` vertical scanning circuit, 73, having
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` the same step as that of said
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` horizontal scanning circuit, 72; a
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` horizontal dummy circuit, 74, having
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` the same step as that of said
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` horizontal circuit, 72; a vertical
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` dummy circuit, 75, having the same
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` step as that of said horizontal
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` scanning circuit, 72."
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` This is one of the either -- there are other
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` places.
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` Q Where are the other places?
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` A Let me elaborate on this part here before we
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` move to the other one.
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` In the section that I just referred to, I just
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` read, all four circuit blocks, 72, 73, 74 and 75, they
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` all have the same step and they all have been compared
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` to the horizontal scanning circuit, 72. This implies
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` that the topology of all those circuits -- and since
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` we can see the vertical topology and we can see now
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` that the layout, at least the extent, the physical
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` extent of the circuits, they are also depicted
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` identical in the circuit, and that the 72 and 73
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` perform the same or similar function to address the
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` display. Those are all the shift registers as
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` Figure 4 discloses.
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` Q Shift registers or horizontal scanning
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` circuits, 72, and vertical scanning circuits, 73, are
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` they identical?
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` A You may have -- they perform the same function.
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` They have to address the lines in order to -- in one
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` case they need to feed the -- the -- in the vertical
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` shift register, they need to control the scanning
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` lines. In this case, they address one line at a time.
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` In the horizontal shift register, they need to
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` control the flow of the data to the pixels. There
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` are --
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` Q Is that the same function?
`
` A That's what I'm about to explain.
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` There are different designs. One of the
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` simplest designs that was early on was to have --
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` address one column at a time and sample a single video
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` line and then feed the data from the video line to
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` that particular column and then move to the next one,
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` to the next one and the next one. That is one of the
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` early designs.
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` There have been other designs since that
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` original one where you can address blocks of data. In
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` either case, the role of the shift register is to
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` address either a single line or a block of lines.
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` The circuit that you have inside will have to
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` take into consideration the speed with which you're
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` going to operate the circuit. The speed in the
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` vertical shift register is slower than the speed of
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` the horizontal shift register.
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` Q This has nothing to do with my question. Your
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` counsel can ask you this on redirect.
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` But my question is, are the circuits in
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` vertical scanning circuit, 73, identical to the
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` circuits in horizontal scanning circuit, 72?
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` A In the section that I just read, they refer to
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` having the same step fabricated with the same material
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` and they have the same surface topology. They perform
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` the same function, however, and that makes them both
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` shift registers, but there may be variations in the
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` length of some devices as the speed -- or the width of
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` the devices as the speed of the two circuits may be
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` different, the operating speed of the two circuits may
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` be different.
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` Q Do the vertical shift registers provide any
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` data to the pixel area?
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` A The vertical shift registers? They control the
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` scan lines, the gate lines.
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` Q Do the horizontal shift registers have anything
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` to do with turning transistors on or off?
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` A The horizontal shift registers provide the data
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` to the column.
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` Q So is the answer "No"?
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` A With respect to the question do the vertical
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` shift registers provide any -- to which question?
`
` Q Take that.
`
` A Excuse me.
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` Q Let's answer that one.
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` A Do the vertical shift registers provide any
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` data to the -- and I said the vertical shift registers
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` control the scan lines, so they do not provide data in
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` the sense that someone skilled in the art will
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` understand it is the information that you apply to the
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` columns.
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` Q Does the horizontal shift register or the
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` horizontal scanning circuit control turning the
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` transistors in the pixel area on or off?
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` A The horizontal shift register controls the flow
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` of data to the transistors. They do not control
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` whether the -- the address transistor at the
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` cross-section of a scan line or data line will be on
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` or off.
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` Q Is turning a transistor on or off a different
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` function than providing data to the transistor?
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` A If the level of voltages that are applied and
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` where those voltages are applied, which is different,
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` the both circuits feed a voltage down a line -- in one
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` case, in the case of the scanning line, the voltage is
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` applied to the gate line and, depending on the magnet
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` and the voltage and polarity, the gate turns the
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` device on or off.
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` In the case of the data that are applied to the
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` source or drain of the transistors, that voltage then
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` is fed into the pixel electrode when the gated
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` transistor has turned the device on.
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` Q Isn't providing data to a transistor a
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` different function than turning a transistor on or
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` off?
`
` A The level of voltages are different. As far as
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` the circuit that controls the flow information
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` selecting the line, that will be the same.
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` But let me back off a little bit here. In the
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` shift register, the role of the shift register is to
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` select something, and in that select -- selection is
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` happening by having one voltage in that line that you
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` are selecting out of many lines, that voltage to be
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` different than other -- all the other lines.
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` In the shift register, there may be other
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` components, too. There may be buffers, and the
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` buffers are -- can be as small as a circuitry that
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` will be able to charge a long line to be able to
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` provide the current for the line to be.
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` So the horizontal shift register and the
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` vertical shift register may include some additional
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` components. The horizontal shift register is turning
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` on or off not the transistor at the pixel, but it's
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` turning on or off another transistor, and that
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` transistor controls to which column you're going to
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` feed the data.
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` So there is a shift register and there are
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` additional components. The role of the shift register
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` is to turn on and off something. In the horizontal
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` shift register, the turning on and off, another
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` transistor which controls which data line will be
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` selected, and that's a vertical line. And that
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` vertical line, then, has been fed the data to the
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` display.
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` So as far as the shift register, it's still the
`
` same thing. It's controlling which one out of many
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` transistors will be on. That transistor is going to
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` feed whatever is at the source or drain of that
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` transistor is going down to the column -- the vertical
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` columns.
`
` Q The horizontal scanning circuit, 72, and the
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` vertical scanning circuit, 73, are they
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` interchangeable?
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` A The whole block or just the shift register?
`
` Q The whole block.
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` A The whole block may contain some additional
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` components within.
`
` Q Does that mean no?
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` Are you saying they are interchangeable or are
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` not interchangeable?
`
` A Well, depending upon the design. And as I said
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` earlier, there may be timing differences between the
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` 72 and 73 which will render some of the
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` interconnections within the transistor to be different
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` of 72 and 73.
`
` Q Are you saying that, in general, vertical
`
` scanning circuit, 73, and horizontal scanning
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` circuits, 72, would be interchangeable?
`
` Is that what you're saying?
`
` A I would say that whether you can plug in -- one
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` in inverse to the other one will depend upon the
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` particular design for the particular display. In
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` general, one cannot make that assumption, that you can
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` just rotate the display and then you get the same
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` functionality. Because there are differences within.
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` The shift register itself may be the same. The shift
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`
` register controls a selection process.
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` What is the additional component that you may
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` have? Whether that is a buffer, as I mentioned
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` earlier, or a control transistor that will feed the --
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` connect the vertical lines with the video lines, those
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` are different.
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` So the shift register itself may be the same,
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` but they maybe include some additional transistors or
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` components within those circuits.
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` Q Figure 7 doesn't talk about shift registers.
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` It talks about a horizontal scanning circuit and
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` vertical scanning circuit.
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` Would you agree that the horizontal scanning
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` circuit has output to the source/drain level of
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` metalization in the pixel area?
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` A Correct.
`
` Q Would you agree that the vertical scanning
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` circuit has output on the gate level of metalization
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` on the pixel area?
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` A Correct.
`
` Q Isn't that a difference between the horizontal
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` scanning circuits and vertical scanning circuits?
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` A In principle, the horizontal controls the
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` horizontal lines -- so the horizontal circuits control
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` the gate lines and the vertical circuits control the
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` data lines.
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` Q So they're different, aren't they?
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` A They're different as to where the output has
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` been fed.
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` Within the horizontal and vertical shift
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` register, there may be components that those
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` components will be identical. There could be some
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` additional components that may render differences in
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` the functionality. But it is -- there may be some
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` components which may occupy a great deal of the area,
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` and those components may be identical.
`
` Q But some of the components inevitably would be
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` different between the vertical scanning circuit and
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` horizontal scanning circuit, wouldn't they?
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` A Some components, depending upon the designs,
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` will be different. But what will be different will be
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` the difference in the design or the layout or how some
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` of the lines are -- where do they feed.
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` But as far as how they're fabricated, what are
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` the materials and what is the physical extent of the
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` entire circuitry and the steps that are created, those
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` are -- will be the same because they're all fabricated
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` at the same time, with the same materials.
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` Q Does Sono disclose anything about what is
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` contained within the horizontal scanning circuits, 72
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` and 73?
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` A It discloses what it is contained in the
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` circuitry of the Figures 4, and it will assume that
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` someone skilled in the art will understand what is, in
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` general, a horizontal and vertical scanning circuit.
`
` Q So is the only disclosure of what's in the
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` vertical scanning circuit and the horizontal scanning
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` circuit the labels in Figure 4, horizontal shift
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` register, vertical shift register?
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` A I believe so.
`
` Q You mentioned that Sono
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