` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` INNOLUX CORPORATION, )
` )
` Petitioner, )
` )
` vs. ) IPR2013-00038
` ) U.S. Pat. No.
` SEMICONDUCTOR ENERGY ) 7,956,978
` LABORATORY CO., LTD., )
` )
` Patent Owner. )
`
` The videotaped deposition of ROGER
`STEWART, called by the Petitioner for examination,
`pursuant to Notice, and pursuant to the applicable
`rules, taken before Sandra L. Rocca, CSR, CRR, at
`115 South LaSalle Street, Chicago, Illinois, on
`the 22nd day of August, 2013, at the hour of
`9:41 a.m.
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`312-442-9087
`
`Veritext Chicago Reporting Company
`800-248-3290
`
`847-406-3200
`
`CMI Exhibit 1014
`Page 1
`
`
`
`Page 2
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` APPEARANCES:
`
` JEFFER MANGELS BUTLER & MITCHELL, LLP
` By: MR. GREGORY S. CORDREY
` 3 Park Plaza, Suite 1100
` Irvine, CA 92614
` (949) 623-7200/Fax: (949) 623-7202
` gcordrey@jmbm.com
` appeared on behalf of the
` Petitioner;
`
` STEPTOE & JOHNSON, LLP
` By: MR. STANLEY A. SCHLITTER
` 115 South LaSalle Street
` Chicago, IL 60603
` (312) 577-1250/Fax: (312) 577-1370
` sschlitter@steptoe.com
` -and-
` STEPTOE & JOHNSON, LLP
` By: MR. DOUGLAS R. PETERSON
` 2121 Avenue of the Stars, Suite 2800
` Los Angeles, CA 90067
` (310) 734-3269/Fax: (310) 734-3169
` dpeterson@steptoe.com
`
` appeared on behalf of the
` Patent Owner.
`
` Also Present:
`
` Mr. Michael Prager, Videographer
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 2
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`
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` I N D E X
`W I T N E S S P A G E
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`Page 3
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`R O G E R S T E W A R T
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`E X A M I N E D B Y
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` M r . C o r d r e y 5
` M r . S c h l i t t e r 2 1 7
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` E X H I B I T S
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`N U M B E R P R E S E N T E D
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`D e p o s i t i o n E x h i b i t
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`N o . 1 0 0 1 r e m a r k e d
` a s 1 0 0 6 U . S . P a t . N o . 7 , 9 5 6 , 9 7 8 4
`N o . 1 0 0 3 r e m a r k e d
` a s 1 0 0 7 U . S . P a t . N o . 5 , 5 1 3 , 0 2 8 4
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`N o . 1 0 0 4 r e m a r k e d
` a s 1 0 0 8 U . S . P a t . N o . 5 , 5 0 4 , 6 0 1 4
`N o . 2 0 1 1 r e m a r k e d
` a s 1 0 0 9 R . S t e w a r t D e c l a r a t i o n 4
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`N o . 1 0 1 0 " P o l y c r y s t a l l i n e S i l i c o n
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` S p e e d I n t e g r a t e d
` S c a n n e r s 2 0 8
`N o . 1 0 1 1 " I n t e g r a t e d D r i v e r
` C i r c u i t r y f o r A c t i v e
` M a t r i x L i q u i d C r y s t a l
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`312-442-9087
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`Veritext Chicago Reporting Company
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`847-406-3200
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`CMI Exhibit 1014
`Page 3
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` (Documents presented as Deposition 09:41:46
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` Exhibit Nos. 1001, 1003, 1004 and 2011 09:41:46
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` for identification.) 09:41:46
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` VIDEOGRAPHER: My name is Michael Prager 09:42:48
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`representing Veritext. The date today is 09:42:50
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`August 22nd, 2013 and the time is approximately 09:42:52
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`9:41 a.m. 09:42:55
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` This deposition is being held in the 09:42:58
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`office of Steptoe & Johnson located at 115 South 09:43:00
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`LaSalle Street, Suite 3100, Chicago, Illinois 09:43:04
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`60603. 09:43:07
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` The caption of this case is Innolux 09:43:08
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`Corporation versus Semiconductor Energy Laboratory 09:43:11
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`Co., Ltd. in the United States Patent and 09:43:15
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`Trademark Office before the Patent Trial and 09:43:17
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`Appeal Board, IPR 2013-00038. The name of the 09:43:19
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`witness is Roger Stewart. 09:43:25
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` At this time the attorneys will identify 09:43:27
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`themselves and the parties they represent, after 09:43:28
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`which our court reporter, Sandra Rocca of 09:43:31
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`Veritext, will swear in the witness and we can 09:43:34
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`proceed. 09:43:34
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` MR. CORDREY: Greg Cordrey from Jeffer 09:43:38
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`Mangels Butler & Mitchell on behalf of Petitioner, 09:43:41
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`Innolux. 09:43:42
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 4
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`
`
`Page 5
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` MR. SCHLITTER: Stan Schlitter and Doug 09:43:43
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`Peterson of Steptoe & Johnson on behalf of the 09:43:45
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`patent owner, Semiconductor Energy Laboratory 09:43:48
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`Company, Ltd. 09:44:01
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` ROGER STEWART, 09:44:01
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`having been first duly sworn, was examined and 09:44:01
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`testified as follows: 09:44:01
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` EXAMINATION 09:44:02
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`BY MR. CORDREY: 09:44:02
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` Q. Good morning, Mr. Stewart. 09:44:03
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` A. Good morning. 09:44:04
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` Q. As you heard, I represent Innolux 09:44:05
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`Corporation, the Petitioner in this Inter Partes 09:44:08
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`review proceeding. Today I'll be asking you some 09:44:11
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`questions about your opinions in this proceeding. 09:44:14
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` You understand that you've been sworn 09:44:16
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`under oath to tell the truth? 09:44:19
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` A. Yes. 09:44:21
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` Q. You've had your deposition taken before, 09:44:21
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`I take it? 09:44:25
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` A. Yes. 09:44:25
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` Q. How many times? 09:44:26
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` A. I haven't counted, a couple dozen times 09:44:26
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`or so. 09:44:29
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` Q. Although you're familiar with the 09:44:30
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`847-406-3200
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`CMI Exhibit 1014
`Page 5
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`Page 6
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`procedure, just a couple other ground rules I'm 09:44:34
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`sure you're familiar with. 09:44:37
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` First, it's going to be that the 09:44:39
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`proceeding is going to take place where I'll ask 09:44:40
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`you questions. If you understand my questions, 09:44:42
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`you'll answer them. From time to time your 09:44:44
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`counsel may interpose objections. Most of those 09:44:46
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`are for the record. Unless he instructs you not 09:44:48
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`to answer, you understand that you have to answer 09:44:51
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`the question. 09:44:53
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` Do you understand those instructions? 09:44:54
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` A. Yes. 09:44:55
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` Q. At the end of this process, we're going 09:44:55
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`to have a deposition transcript, a written record 09:44:59
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`of the questions and answers. You're going to 09:45:02
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`have an opportunity to review that and make any 09:45:04
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`changes. Just so you understand, any changes you 09:45:07
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`make to your testimony, we can comment on that at 09:45:11
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`a later proceeding or at a later time. 09:45:13
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` Do you understand that? 09:45:17
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` A. Yes. 09:45:17
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` Q. I will do my best to ask you clear and, 09:45:17
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`you know, intelligible questions. If for whatever 09:45:25
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`reason my questions aren't clear, let me know and 09:45:29
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`I will do my best to rephrase those. If you 09:45:33
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`CMI Exhibit 1014
`Page 6
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`Page 7
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`answer my question, I'll assume that you 09:45:36
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`understood the question. 09:45:37
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` Is that fair? 09:45:38
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` A. Yes. 09:45:39
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` Q. Do you have any questions for me about 09:45:40
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`our proceeding here today? 09:45:43
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` A. No. 09:45:44
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` Q. I've handed you a number of exhibits. 09:45:53
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`Let's start with Exhibit 1001, which is the U.S. 09:45:58
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`Patent 7,956,978. 09:46:05
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` Do you have that? 09:46:09
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` A. Yes. 09:46:10
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` Q. If you could, take a minute and take a 09:46:10
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`look at it. You recognize this to be the -- I'm 09:46:12
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`going to refer to this as the '978 patent. 09:46:18
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` A. Yes. 09:46:21
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` Q. Have you seen this document before? 09:46:21
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` A. Yes. 09:46:25
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` Q. Okay. And when was the last time you 09:46:26
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`read the '978 patent? 09:46:30
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` A. Two days ago, I think. 09:46:35
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` Q. Was that in connection with your 09:46:40
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`preparation for today's deposition? 09:46:42
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` A. Yes. 09:46:43
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` Q. What else did you do in connection with 09:46:44
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`CMI Exhibit 1014
`Page 7
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`
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`Page 8
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`your preparation for today's deposition? 09:46:46
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` A. I reviewed or I -- I read a few 09:46:47
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`additional documents that I hadn't read to that 09:46:57
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`point, like the original application going back 09:47:00
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`into 2012. And I -- there were -- so I wanted to 09:47:06
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`make sure that I had read every document that I 09:47:11
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`intended to read and then I also reviewed all the 09:47:13
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`documents that I had read. 09:47:17
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` Q. I've handed you another exhibit that's 09:47:20
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`been identified as Exhibit 2011. This is your 09:47:24
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`declaration. If you'll take a minute and confirm 09:47:32
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`that this is indeed the declaration that you 09:47:42
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`submitted in this matter. 09:47:43
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` A. Yes. 09:47:46
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` Q. If you would turn to page 60 of your 09:47:51
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`declaration -- you can unclip it if it's helpful. 09:47:55
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` A. Yes. 09:48:07
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` Q. There's an Appendix A. It says 09:48:08
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`"Materials considered by Roger Stewart." 09:48:12
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` Do you see that? 09:48:13
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` A. Yes. 09:48:13
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` Q. Are these the materials that you 09:48:14
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`reviewed in preparation for your deposition today? 09:48:17
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` A. Yes, some I considered more thoroughly 09:48:19
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`than others. I -- I don't believe I read the 09:48:56
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`CMI Exhibit 1014
`Page 8
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`Page 9
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`entirety of Dr. Silzars' expert opinion, but I 09:48:58
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`think that's pretty much what I -- what I used as 09:49:19
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`my reading list and went through. 09:49:22
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` Q. You mentioned that there were some 09:49:24
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`additional documents that you -- you may have 09:49:26
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`looked at. 09:49:27
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` Are there documents right now that you 09:49:30
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`can recall looking at that aren't listed on this 09:49:32
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`list in Appendix A? 09:49:34
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` A. No. I was -- I was -- I was trying -- 09:49:36
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`working late as it was to catch up on -- make sure 09:49:45
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`that I had carefully reviewed everything that was 09:49:48
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`on this list, excepting of course Silzars' report. 09:49:51
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` Last night I went through the -- I just 09:49:58
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`skimmed through the petition for Inter Partes' 09:50:01
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`review. I had not looked at that and I looked at 09:50:06
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`it more carefully last night because it was on 09:50:08
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`this list. 09:50:12
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` Q. In preparation for your deposition here 09:50:13
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`today, did you meet with anybody to prepare? 09:50:17
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` A. Oh, yes. 09:50:20
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` Q. Who did you meet with? 09:50:21
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` A. Stan Schlitter and -- and Doug and some 09:50:22
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`of the other people here. 09:50:26
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` Q. Do you recall who some of the other 09:50:28
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`Veritext Chicago Reporting Company
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`847-406-3200
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`CMI Exhibit 1014
`Page 9
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`Page 10
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`people here were? 09:50:30
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` A. One of them, Amanda -- I forgot her last 09:50:31
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`name, but she had worked with me on -- when I was 09:50:37
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`doing the report. 09:50:39
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` Q. And how long did you -- did you meet 09:50:40
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`for -- let me back up. 09:50:45
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` On how many occasions did you meet? 09:50:49
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` A. Three occasions. 09:50:51
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` Q. And when were those occasions? 09:50:53
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` A. Once on Monday, once on Tuesday and once 09:50:54
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`on Wednesday. 09:50:58
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` Q. And how long were those meetings? 09:50:58
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` A. Varied. I think from a couple hours to 09:51:00
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`maybe six or seven hours. 09:51:07
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` Q. Did you do anything else to prepare for 09:51:10
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`your deposition today? 09:51:13
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` A. I did a lot of reviewing of documents, 09:51:14
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`so I was trying the whole -- all the time to spend 09:51:19
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`as much time reviewing documents and kind of 09:51:22
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`refreshing myself on the -- on these matters and I 09:51:27
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`tried to minimize my time in meetings with 09:51:32
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`anybody. 09:51:34
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` Q. In your declaration at page 61, there's 09:51:34
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`an Appendix B, which is captioned as the 09:51:40
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`"Curriculum Vitae of Roger Stewart." 09:51:43
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`CMI Exhibit 1014
`Page 10
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`Page 11
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` Do you see that? 09:51:45
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` A. I'm sorry. Where are you? 09:51:46
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` Q. I'm at Appendix B of your declaration, 09:51:49
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`which is -- looks like it's pages 61 and 62. And 09:51:51
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`there's an Appendix C, which is a list of 09:51:57
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`publications and patents. 09:51:59
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` A. Okay. Yes. 09:52:01
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` Q. Are these current? 09:52:03
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` A. Reasonably current. I have a lot of 09:52:07
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`patents, so there's occasional patents. I haven't 09:52:28
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`counted -- gone through and counted every one of 09:52:32
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`them in the last few months, but -- so I can't 09:52:37
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`give you an exact count, but it's about 110. 09:52:40
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` Q. Other than the list of patents that you 09:52:42
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`have in -- it looks like Appendix C -- are there 09:52:45
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`any other portions of your curriculum vitae or the 09:52:48
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`related appendices that may not be up-to-date? 09:52:53
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` A. Not to my knowledge. 09:52:57
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` Q. Turning back to Exhibit 1001, which is 09:53:00
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`the '978 patent, what do you understand to be the 09:53:23
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`problem that the '978 patent was directed to 09:53:30
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`solving or problems? 09:53:33
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` A. Three problems. 09:53:35
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` Q. Okay. 09:53:36
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` A. One was the uniformity of the cell gap 09:53:36
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`312-442-9087
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`Veritext Chicago Reporting Company
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`847-406-3200
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`CMI Exhibit 1014
`Page 11
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`Page 12
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`and achieving better optical quality by having a 09:53:44
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`more uniform gap. Second key problem was at the 09:53:49
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`same time improving or at least not degrading the 09:53:55
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`integrity of the seal; and thirdly, to improve the 09:54:02
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`yield, in other words, to do everything in such a 09:54:13
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`way as to improve the tolerance of the design to 09:54:16
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`short defects that were known to occur in the 09:54:25
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`mid-'90's so that a defect did not destroy the 09:54:29
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`entire display. That was a big problem then. So 09:54:34
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`those were the three problems that were the focus 09:54:36
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`of the -- of this patent. 09:54:40
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` Q. When you say improve "the uniformity of 09:54:42
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`the cell gap," can you elaborate what you mean by 09:54:46
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`that? 09:54:49
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` A. The two twisted pneumatic pixels are -- 09:54:49
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`their performance varies according to how thick, 09:55:04
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`how much spacing there is between the pixel and 09:55:06
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`the counter electrode and I think the -- somewhere 09:55:08
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`between -- you can only tolerate a variation of 09:55:15
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`about 1/10th or 2/10ths of a millimeter in 09:55:18
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`difference. 09:55:24
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` So it's typically 4 to 6 millimeters -- 09:55:24
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`excuse me -- 4 to 6 microns and if there's a 09:55:28
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`difference of -- let me correct that. 09:55:31
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` It's 4 to 6 microns thick and a 09:55:33
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 12
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`Page 13
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`variation of more than 0.1 or 0.2 microns will 09:55:36
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`create unacceptable modeling, nonuniformities, 09:55:41
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`other -- other image defects. So the -- you have 09:55:47
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`to -- you have to maintain very tight control of 09:55:54
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`that -- of that gap. 09:55:58
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` And it's done partly by having a uniform 09:56:00
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`gap where you have the seal and it's also done by 09:56:05
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`adding spacers and other structures into the 09:56:09
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`interior of the array so that you maintain a 09:56:13
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`constant cell gap everywhere across the display. 09:56:17
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` Q. Is there a particular aspect of the '978 09:56:20
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`patent that's directed to the -- this cell gap 09:56:24
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`uniformity that you just described? For example, 09:56:29
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`you listed -- you referenced the seal and then you 09:56:33
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`also referred to adding spacers and other 09:56:42
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`structures. 09:56:43
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` What's your understanding in terms of 09:56:45
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`which aspect the '978 patent -- if any or both, 09:56:47
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`the '978 patent relates to? 09:56:52
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` A. The '978 patent is concerned -- again, I 09:56:54
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`mentioned it's also concerned with the seal 09:56:59
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`integrity and the manufacturing, but to the extent 09:57:02
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`it's concerned about the uniformity, it's 09:57:06
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`concerned with the seal area. 09:57:08
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` Q. And when you say it's "concerned with 09:57:12
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 13
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`Page 14
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`the seal area," can you elaborate on what you mean 09:57:14
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`by that? 09:57:18
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` A. The '978 patent wants a -- to have a 09:57:19
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`uniform spacing between the two glass plates 09:57:33
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`everywhere in the seal, on the right side, left 09:57:35
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`side, top and bottom. 09:57:38
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` The '978 also wants the -- wants to 09:57:41
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`minimize the topology in many ways in the seal 09:57:45
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`also. It tries to create not just a very uniform 09:57:50
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`seal, but one that's locally uniform so that it 09:57:54
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`doesn't have a lot of -- any more bumps in it than 09:57:56
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`it has to. And that makes a stronger seal and 09:57:59
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`less likely that you could crush different 09:58:02
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`elements and cause damage. I can explain if you 09:58:05
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`want. 09:58:09
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` Q. If you wouldn't mind, please. 09:58:09
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` A. One of the other -- one of the other 09:58:11
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`concerns with a -- it's not just when you say I 09:58:13
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`want a uniform seal, you -- that normally means 09:58:17
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`you're concerned about the highest structures in 09:58:22
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`the seal area. You want those to have the same 09:58:24
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`total height, but you also don't want to have just 09:58:26
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`one high structure all by itself because while 09:58:30
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`that may give you a uniform seal, the forces on 09:58:35
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`that small structure could damage it. 09:58:39
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 14
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`Page 15
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` So you need to include a high enough -- 09:58:42
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`I think as Hatalis put it -- density of those 09:58:46
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`structures all around your seal area to make sure 09:58:48
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`that the -- you're controlling the stress levels 09:58:51
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`on the -- on the protrusions within -- within the 09:58:55
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`cell area -- within the seal area and there's a 09:58:59
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`lot of discussion of that in the -- in the '978 09:59:05
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`patent. 09:59:09
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` It's very concerned with that and it 09:59:10
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`does a -- there's a lot of discussion, different 09:59:12
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`embodiments for how to not just control the 09:59:15
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`uniformity of the cell gap, but how to do it in 09:59:17
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`such a way as to minimize excessive stress on the 09:59:22
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`structures that are -- that are controlling it. 09:59:26
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` Q. What's your understanding as to 09:59:28
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`generally how the '978 addresses those issues? 09:59:30
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` A. It incorporates dummy structures into 09:59:36
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`the -- into the cell -- into the cell -- seal 09:59:44
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`regions. 09:59:47
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` Q. When you use the term "dummy 09:59:52
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`structures," what do you mean by that? 09:59:57
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` A. Those are the ones generally referred to 10:00:00
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`as these conductive layers. They're -- they're 10:00:06
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`devices that are often called dummy because they 10:00:14
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`serve no electrical function within -- within the 10:00:17
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 15
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`Page 16
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`display. They are always isolated from the power 10:00:19
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`lines so they're -- they're not powered. The '978 10:00:28
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`patent goes further and isolates them from each 10:00:35
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`other as well. 10:00:39
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` And the -- the '978 also teaches how to 10:00:41
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`make sure that the height of those -- of the 10:00:55
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`structures that are in the seal area are -- are 10:00:58
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`uniform on all sides of the display and are 10:01:02
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`uniform within different portions of those sides. 10:01:04
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` Q. When you say the heights are uniform, 10:01:10
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`can you explain that? Are they uniform across the 10:01:15
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`substrate? Are they uniform in a -- along a 10:01:17
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`particular edge? What do you mean by -- when you 10:01:21
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`say they're uniform? 10:01:24
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` A. The intent is that they're -- it's -- is 10:01:26
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`make sure that they're as uniform as possible 10:01:31
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`within the sealing region. 10:01:33
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` Q. And the sealing region is the region in 10:01:36
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`which part of the substrate? 10:01:40
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` A. That's around the edge of the substrate. 10:01:41
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` Q. All four -- 10:01:44
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` A. All four edges. The -- you have two -- 10:01:45
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`you have two glass plates that are going to be 10:01:53
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`bonded together with typically an epoxy and that 10:01:56
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`epoxy not only holds them together as a mechanical 10:02:02
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
`
`CMI Exhibit 1014
`Page 16
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`
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`Page 17
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`structural feature, but also serves to -- as what 10:02:06
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`we call a seal so that impurities don't come in 10:02:13
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`from the outside and penetrate into the liquid 10:02:17
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`crystal portion of the display. 10:02:20
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` Liquid crystals are -- are readily 10:02:22
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`degraded by a lot of impurities that will come 10:02:27
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`into the displays and it's well-known in the 10:02:30
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`industry that the seal is often the weak point. 10:02:33
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`If a display fails in life or it fails in the 10:02:37
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`environment, it's usually the seal that will -- 10:02:41
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`that's -- that's the cause of the failure. 10:02:45
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` So there's a lot of effort made to -- to 10:02:47
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`make that seal as strong as possible and to make 10:02:51
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`it as impervious to the -- to the penetration of 10:02:55
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`moisture and other things coming in from the 10:02:59
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`outside as you can. Seals are -- they're trying 10:03:02
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`to make them thinner. They're a millimeter or two 10:03:05
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`wide now. 10:03:09
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` In 1995 they were wider because they 10:03:10
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`were -- but the seal, you can't make the seal any 10:03:16
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`bigger than you -- you try to make the seal as 10:03:20
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`small as you can and have it still work because 10:03:22
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`the seal makes your display bigger. It increases 10:03:24
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`the mullion, which no one wants. 10:03:27
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` Q. You used the term "mullion." 10:03:31
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`CMI Exhibit 1014
`Page 17
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`
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`Page 18
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` What does that mean? 10:03:34
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` A. Okay. When people buy display, they 10:03:35
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`want to see image area. If you buy a cell phone, 10:03:39
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`what you want is a large screen that you can see. 10:03:43
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`What no one wants is a large area around it, a 10:03:46
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`picture frame, if you will, around it which does 10:03:49
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`nothing, and that just wastes area and it wastes 10:03:52
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`money and contributes nothing to the user. 10:03:58
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` So this would be the mullion on -- on 10:04:00
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`this display, the black area that -- that cannot 10:04:03
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`show an image. So the seal area is part of the 10:04:06
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`mullion. In other words, so no one wants to make 10:04:11
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`the sealing region any bigger than it has to be 10:04:14
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`because it's -- it's wasted money and it's wasted 10:04:17
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`space. 10:04:22
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` So the tradeoff in the industry is you 10:04:23
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`try to -- you have to have a certain strength and 10:04:28
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`a certain moisture, you know, performance without 10:04:30
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`making the seal any bigger than it has to be. 10:04:36
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` Q. Let's look at page 21 of your 10:04:40
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`declaration and specifically, I'll refer you to 10:04:53
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`paragraph 61. I'll give you a minute to -- or as 10:05:07
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`much time as you need to read paragraph 61. 10:05:11
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` What I'm focused on or I'm going to be 10:05:14
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`asking you questions about is your understanding 10:05:17
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
`
`CMI Exhibit 1014
`Page 18
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`Page 19
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`about the meaning or the definition of the first 10:05:19
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`and second conductive layers. 10:05:21
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` Do you need a minute to read it? 10:05:25
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` A. I do. 10:05:26
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` Q. Okay. Take your time. 10:05:27
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` About -- it looks like the -- towards 10:07:47
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`the bottom of the page in paragraph 61, you state 10:07:50
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`that "One of skill in the art would have 10:07:53
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`understood that in this context, first and second 10:07:55
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`conductive layers formed from a same layer means a 10:07:59
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`first and second unitary structure formed from a 10:08:03
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`unitary structure." 10:08:06
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` Do you see that? 10:08:08
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` A. Yes. 10:08:08
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` Q. What do you mean by that? 10:08:09
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` A. Differ