SEL EXHIBIT 2011
`
`INNOLUX CORPORATION V. PATENT OF SEMICONDUCTOR ENERGY
`
`LABORATORY CO., LTD.
`
`lPR2013—00066
`
`
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`INNOLUX CORPORATION V. PATENT OF SEMICONDUCTOR ENERGY
`
`LABORATORY CO., LTD.
`
`lPR2013—00066
`
`
`
`
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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRAIL AND APPEAL BOARD
`
`
`
`INNOLUX‘CORPORATION,
`
`Petit
`
`ioner,
`
`VS.
`
`PATENT OF SEMIC
`
`ONDUCTOR
`
`ENERGY LABORATO
`
`RY CO., LTD.,
`
`Paten
`
`t Owner.
`
`NO.
`
`IPR2013~OOO66
`
`Patent 7,876,413
`
`VIDEOTAPED DEP
`
`OSITION OF MILTIADIS HATALIS,
`‘Irvine, California
`
`PH.D.
`
`Monday, July 1, 2013
`
`Volume I
`
`Reported by:
`
`DENISE BARDSLEY
`
`CSR No. 11241
`
`Job No. 1684547
`
`
`
`
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`PAGES 1 — 197
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRAIL AND APPEAL BOARD
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`Page 2
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`) ) ) ) )
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`
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`INNOLUX CORPORATION,
`
`Petitioner,
`
`VS.
`
`)NO.
`
`IPR2013—OOO66
`
`)Patent 7,876,413
`
`)
`
`) )
`
`) )
`
`PATENT OF SEMICONDUCTOR
`
`ENERGY LABORATORY CO., LTD.,
`
`Patent Owner.
`
`
`
`videotaped deposition of MILTIADIS HATALIS,
`
`PH.D., Volume I,
`
`taken on behalf of Patent Owner, at
`
`3 Park Plaza, Suite 1100, Irvine, California,
`
`beginning at 9:02 a.m. and ending at 6:32 p.m. on
`
`Monday, July 1, 2013, before DENISE BARDSLEY,
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`Certified shorthand Reporter No. 11241.
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`Page 3
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`APPEARANCES:
`
`For Petitioner:
`
`JEFFER MANGELS BUTLER & MITCHELL LLP
`
`BY:
`
`STANLEY M. GIBSON
`
`Attorney at Law
`
`3 Park Plaza, Suite 1100
`
`Irvine, California
`
`92614
`
`(949) 623-7200
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`sgibson@jmbm.com
`
`For The Patent Owner:
`
`STEPTOE & JOHNSON LLP
`
`BY:
`
`STANLEY A. SCHLITTER
`
`Attorney at Law
`
`115 South LaSalle Street, Suite 3100
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`Chicago, Illinois
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`60603
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`(312) 577—1250
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`sschlitter@steptoe.com
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`Page 4
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`APPEARANCES (Continued):
`
`For The Patent Owner:
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`HUSCH BLACKWELL, LLP
`
`BY:
`
`EDWARD D. MANZO
`
`BY:
`
`MARK J. MURPHY
`
`Attorneys at Law
`
`120 South Riverside Plaza, Suite 2200
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`Chicago, Illinois
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`60606
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`(312) 655-1500
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`edward.manzo@huschblackwell.com
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`mark.murphy@huschblackwell.Com
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`ROBINSON INTELLECTUAL PROPERTY LAW OFFICE
`
`3975 Fair Ridge Drive, Suite T20 North
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`Fairfax, Virginia
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`22033
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`(571) 434—6789
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`(No appearance.)
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`Videographer:
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`SCOTT SLATER, VERITEXT
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`INDEX
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`Page 5
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`WITNESS
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`EXAMINATION
`
`MILTIADIS HATALIS, PH.D.
`
`VOLUME I
`
`BY MR. MANZO
`
`8
`
`EXHIBITS
`
`EXHIBIT
`
`DESCRIPTION
`
`Exhibit 2008
`
`Display Research
`
`PAGE
`
`22
`
`Laboratory website
`
`material
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`Exhibit 2009
`
`Fig. 1B, Prior Art
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`82
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`Exhibit 2010
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`Fig. 2C, Prior Art
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`Irvine, California, Monday, July 1, 2013
`
`9:02 a.m.
`
`Page 6
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`THE VIDEOGRAPHER: Good morning.
`
`We are on the record at 9:02 a.m. on July
`
`lst, 2013., This is the video—recorded deposition of
`
`Dr. Milt Hatalis. My name is Scott Slater, here
`
`with our court reporter, Denise Bardsley. We are
`
`here from Veritext Legal Solutions at the request of
`
`the patent owner.
`
`This deposition is being held at 3 Park
`
`Plaza, Suite 1100,
`
`in the city of Irvine, California
`
`92614.
`
`The caption of this case is Innolux
`
`Corporation versus Patent of Semiconductor
`
`Laboratory Co., Ltd., Case No.
`
`IPR2013~00066, Patent
`
`7,876,413.
`
`Please note that audio and video recording
`
`will take place unless all parties agree to go off
`
`the record.
`
`Microphones are sensitive and may pick up
`
`whispers, private conversations or cellular
`
`interference.
`
`I am not authorized to administer an oath,
`
`I am not related to any party in this action, nor am
`
`
`
`
`
`I financially interested in the outcome in any way.
`
`
`1_
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`312
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`May I please have an agreement from all
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`Page 7
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`parties that we may proceed.
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`MR. MANZO: Agreed.
`
`MR. GIBSON: That's fine with me.
`
`THE VIDEOGRAPHER:
`
`Thank you very much.
`
`At this time will counsel and all present
`
`please identify themselves for the record.
`
`MR. MANZO:
`
`For the plaintiff —— sorry.
`
`For the patent owner, my name is Edward
`
`Manzo, M—a—n—z—o.
`
`With me are Mark Murphy and Stanley
`
`Schlitter.
`
`Mr. Murphy and I are from the firm of Husch
`
`Blackwell, LLP in Chicago. Mr. Schlitter is from
`
`Steptoe & Johnson.
`
`MR. GIBSON:
`
`Stan Gibson on behalf of the
`
`petitioner.
`
`THE VIDEOGRAPHER:
`
`Thank you very much.
`
`Will the court reporter please administer
`
`the oath.
`
`//
`
`//
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`MILTIADIS HATALIS, PH.D.,
`
`having been administered an oath, was examined and
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`testified as follows:
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`Page 8
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`BY MR. MANZO:
`
`EXAMINATION
`
`Q
`
`Good morning, Professor. My name is Edward
`
`Manzo, and I‘m here on behalf of SEL to ask you some
`
`questions about topics that are raised in your
`
`' declaration and otherwise.
`
`A
`
`Q
`
`Good morning.
`
`Could you please state your name.
`
`A Miltiadis Hatalis.
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`And do you live in Pennsylvania somewhere?
`
`In Bethlehem, Pennsylvania.
`
`Thank you.
`
`How old are you, Doctor?
`
`54.
`
`I'm going to hand you what's been
`
`previously filed as Exhibit 1005.
`
`It purports to be
`
`the declaration of Miltiadis Hatalis.
`
`Could you just take a quick look at that
`
`and tell me if that is the declaration that you
`
`signed?
`
`
`
`
`
`Yes, it is.
`A
`
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`Page 9
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`Q
`
`Thank you.
`
`How did you prepare for today's deposition?
`
`A
`
`I reviewed the petition,
`
`I reviewed my
`
`declaration,
`
`I reviewed the board decision,
`
`I
`
`reviewed the rehearing request by the patent owner,
`
`and I reviewed the decision of the board from the
`
`rehearing, and I also reviewed the initial response
`
`of the patent owner.
`
`Q
`
`A
`
`Did you look at the challenged patent?
`
`Yes.
`
`I also looked at the '413, and I look
`
`at the two prior art patents, namely the one from
`
`Sukegawa and Nakamoto.
`
`Q
`
`For convenience, why don't we refer to
`
`those that way.
`
`We'll call Exhibit 1003, which is U.S.
`
`Patent 5,636,329 the Sukegawa patent.
`
`Is that okay with you?
`
`It will be fine.
`
`And we'll call the Japanese reference to
`
`A
`
`Q
`
`Nakamoto, N—a—k—a—m—o—t—o, and that was filed as
`
`Exhibit 1004, we'll call that Nakamoto.
`
`Is that all right with you?
`
`A
`
`Q
`
`That will be fine.
`
`Okay.
`
`Thank you.
`
`
`
`
`
`Did you meet with anybody in preparation
`
`
`
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`Page 10
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`for today's deposition?
`
`A
`
`Yes.
`
`I met with my counsel, Stan Gibson,
`
`and his colleague, Ali Shalchi.
`
`Q
`
`A
`
`About how long did you meet?
`
`I arrived in the area Wednesday night,
`
`so
`
`we met
`
`the last four days.
`
`Q
`
`Professor, do you know how you came to be
`
`hired or why you were hired for this expert
`
`engagement?
`
`A
`
`I am a professor in the field of
`
`microelectronics and,
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`in particular, my group and my
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`Ph.D.
`
`thesis is advancing the technology of
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`thin—film transistors, which is the main electronic
`
`device used in flat panel displays and,
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`in
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`particular,
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`the active metrics liquid crystal
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`displays.
`
`I'm director of a laboratory which I have
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`founded in the early '90s at Lehigh, which is called
`
`the Display Research Laboratory, and I have
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`published extensively in this field, both in
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`scientific journals and in conference proceedings.
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`I also published two book chapters,
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`so I
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`consider myself to be expert in this field.
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`Q
`
`Have you actually worked in the
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`microelectronics field producing any products,
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`commercial products?
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`A
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`I have been in academia and I have worked
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`with companies as a consultant, but
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`the academic
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`institution that I have been as a student or, for
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`the last 25 years, as professor is a nonprofit
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`institution so we do research. We do not produce
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`and sell commercial product.
`
`But we produce prototype displays and
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`produce processes, device structures, materials that
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`different companies may adopt in their manufacturing
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`process for making displays.
`
`Q
`
`Can you tell me the difference between a
`
`process engineer and a circuit design engineer with
`
`respect to the semiconductor field?
`
`A
`
`A process engineer and a circuit design
`
`engineer —— a process engineer deals more with the
`
`actual fabrication,
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`so it deals with the different
`
`processes that are used to deposit material,
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`to lay
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`down materials,
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`to remove materials,
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`to clean
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`substrates,
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`to do a process known as a
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`photolithographic process, which defines the areas
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`that will remain on the substrate during an etching
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`process.
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`So it's involved with all the different
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`fabrication steps that are used to implement
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`the
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`design into a physical product.
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`
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`
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`Whereas a design engineer, he deals with
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`
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`Page 12
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`the abstract elements.
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`He deals with device models,
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`and he does not fabricate the components, but he is
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`designing them using different softwares to find out
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`what would be the electrical performance of a system
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`before it gets fabricated so it can do changes in
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`the design, say the width or the length or the line,
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`in order to determine whether the different electro
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`characteristics, such as resistance or capacitance,
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`will affect the performance and whether the system
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`specification at the end will be the desired ones.
`
`Q
`
`Do those persons have different backgrounds
`
`and skill sets?
`
`A
`
`The circuit design and process engineers,
`
`well,
`
`they start from —— if you start from the
`
`field, say, of electrical engineering,
`
`the
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`background education is going to be the same.
`
`For example, our electrical engineer
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`students take courses in circuit design,
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`they also
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`take courses in microelectronic technology,
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`so they
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`are exposed to the whole spectrum of what it takes
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`to design a system as well as to fabricate the
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`system.
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`Now, once such engineer goes into a
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`company,
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`the specific tasks that I will be assigned,
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`
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`
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`they will probably be one or the other. But if he
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`Page 13
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`change positions and if his education has been good,
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`he could move from processing to circuit design and
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`from circuit design to processing.
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`But after a while,
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`I would think that some
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`people will tend to become known as —— for one
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`aspect and they maybe enjoy doing more Circuit
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`design and enjoy doing more process engineer. But
`
`it is not one unique answer.
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`It depends on the
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`interest of the people and the opportunity they have
`
`in life and so on.
`
`Q
`
`Thank you.
`
`Would you consider yourself closer to a
`
`circuit designer or a process engineer?
`
`A Well,
`
`I am a professor,
`
`so —— and I
`
`teach
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`courses related to circuit design.
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`For example,
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`I
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`teach the course on very large—scale integration,
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`VLSI.
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`That course deals with the design of circuits
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`that go into electronic systems, but I also have a
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`laboratory that we do actual fabrications and deal
`
`with materials and processes, so I am, by virtue of
`
`my position, exposed to both.
`
`Q
`
`I see.
`
`Do you teach any courses in process
`
`engineering for semiconductors?
`
`
`
`A
`
`I have taught a course, "Microelectronic
`
`
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`Page 14
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`Technology," and I taught it several
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`times when I
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`was first started as a professor. Right now I'm
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`teaching a course in VLSI design, and as a part of
`
`that course there is a section that deals with the
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`fabrication.
`
`Q
`
`I see.
`
`Now,
`
`I see from an attachment to your
`
`exhibit —— sorry —- your Appendix A on Exhibit 1005,
`
`right after page 51,
`
`that you've been involved in
`
`some patent litigation cases starting in 2001;
`
`is
`
`that right?
`
`A
`
`Q
`
`That's correct.
`
`And it looks like in 2001 you were hired to
`
`be a witness or an expert for Sanyo against SEL;
`
`is
`
`that right?
`
`A
`
`Correct.
`
`I think it was SEL against Sanyo.
`
`I am not an expert who is against who.
`
`I
`
`represented Sanyo.
`
`Q
`
`And you were an expert for CMO in 2007
`
`against SEL?
`
`A
`
`Q
`
`A
`
`Q
`
`Correct.
`
`And you were an expert
`
`in 2008 for CMO?
`
`Correct.
`
`And you were an expert against SEL in a
`
`
`
`
`
`case SEL versus Samsung in 2009?
`
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`Page 15
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` 1
`
`A Correct.
`
`Q
`
`And then you were an expert for CMI
`
`in
`
`2011?
`
`A
`
`Q
`
`Yes.
`
`And you continued as an expert
`
`in 2011 for
`
`Samsung? Yes?
`
`A
`
`Q
`
`Correct, yes.
`
`So,
`
`in a nutshell, for 12 years,
`
`approximately, you have been an expert witness fOr
`
`companies opposing SEL;
`
`is that right?
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS:
`
`The record shows _- this is
`
`what
`
`the record shows, but
`
`I do not choose the
`
`cases.
`
`The different law firms come and hire me.
`
`BY MR. MANZO:
`
`Q What is your relationship with CMO?
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS:
`
`I have been hired by several
`
`law firms to serve as an expert on behalf of the
`
`defendants, which happened to be CMO or CMI. And I
`
`did not deal with CMO directly,
`
`I dealt with the law
`
`firms.
`
`BY MR. MANZO:
`
`Q
`
`Has your experting work in patent
`
`
`
`litigation always been against the patent owner?
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`Page 16
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`A
`
`So far.
`
`The recent —— a new case I have
`
`been asked and I have been retained in which it will
`
`start, if it doesn't settle earlier,
`
`later this
`
`year, and in that case I will represent the patent
`
`owner.
`
`Q
`
`A
`
`Q
`
`But otherwise not?
`
`So far, no.
`
`You have a relationship with the Display
`
`Research Laboratory that I think you mentioned a
`
`moment ago;
`
`is that correct?
`
`A
`
`Q
`
`I am a director of the laboratory.
`
`Who funds the laboratory?
`
`A Well,
`
`the physical infrastructure,
`
`the
`
`construction of the laboratory,
`
`the utilities for
`
`the laboratory,
`
`that is funded by the university.
`
`The university also pays for my nine—month salary.
`
`I am responsible for raising the funds to
`
`cover the actual expenses of consumables and for the
`
`salary and tuition of the graduate students that
`
`a work in the laboratory, as well as for the staff
`
`engineer that works in the laboratory.
`
`Q Where does the capital equipment come from?
`
`A
`
`The capital equipment comes from a variety
`
`of sources.
`
`Some of it are been donated by
`
`
`
`
`
`some of it would come —— we buy from
`industry,
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`special equipment grants that we get from their
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`regular solicitations from the government, different
`
`agencies, or we buy them from the budget of specific
`
`research program.
`
`If, during the research for that
`
`program, we need a particular piece of equipment, we
`
`budget that equipment in that —— in the proposal.
`
`Q
`
`Please tell me whether you have had any
`
`kind of economic support or the Display Research
`
`Laboratory has had any support or donations from any
`
`of the following entities.
`
`Acer?
`
`No.
`
`ViewSoniC?
`
`NO.
`
`A
`
`Q
`
`A
`
`Q Vizio?
`
`A
`
`No.
`
`Q Westinghouse?
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`NO.
`
`Innolux?
`
`No.
`
`CMI?
`
`NO.
`
`CMO?
`
`No.
`
`Professor, without asking you specific
`
`
`
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`
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`Page 18
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`dollar numbers, what portion of your personal
`
`income
`
`comes from expert work for law firms, as opposed to
`
`your compensation from the university for teaching?
`
`And, again,
`
`I don't want any dollar numbers,
`
`just a
`
`percentage.
`
`A Well,
`
`that percentage, it varies from year
`
`to year, and it —— and, as you see, my litigation or
`
`patent involvement work or consulting has been
`
`sporadic.
`
`So if you are talking about a particular
`
`year or you are talking about since 2001?
`
`Q Well, let's start with 2013, year to date.
`
`A
`
`The contribution of the patent litigation
`
`is significant.
`
`Q More than 50 percent?
`
`A
`
`Q
`
`A
`
`Up to now?
`
`Yes.
`
`It may.
`
`I didn't do the calculation.
`
`I
`
`have to do the calculation.
`
`But this is an unusual year, because the ——
`
`some of the legal fees —— some of the work that I've
`
`done in 2012 were paid in 2013,
`so it's always a
`period before you send in an invoice and you get
`
`paid.
`
`So in 2013, it reflects work that was done in
`
`
`
`
`
`2012.
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`Page 19
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` 1
`
`Q
`
`Thank you.
`
`What would you say -— between 2001, between
`
`the interval of 2001 through 2013, what would you
`
`say is the highest percentage in a single year that
`was represented by compensation for working as an
`
`expert witness?
`
`So I'm asking you for a percentage number
`
`and a year in round numbers.
`
`Of the total income earned that year or ——
`
`Yes.
`
`—— compared to my academic year salary?
`
`Total
`
`income earned.
`
`The highest amount total income earned in
`
`A Q
`
`A
`
`Q
`
`A
`
`any year since 2011 -—
`
`Q
`
`A
`
`Q
`
`2001.
`
`Sorry.
`
`2001.
`
`I'm only asking for percentage, not
`
`dollars, again.
`
`A
`
`Right, but I haven't done the calculation.
`
`That's many tax years I have to try to go back and
`
`try to do it.
`
`But in round numbers,
`
`I don't know,
`
`I
`
`cannot give you the exact number, but I would say 30
`
`to 40 percent may have been the highest.
`
`
`
`Have you been an expert
`Q
`
`
`in other
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`Page 20
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`litigations besides patent cases?
`
`A
`
`Q
`
`A
`
`Expert to law firms?
`
`Law firms or others.
`
`I have been an expert and I have a section
`
`in my resume that I built, consultant to industry
`
`since 1997,
`
`so I list a number of companies where I
`
`serve as a technical consultant.
`
`Q What page is that on?
`A
`Page 1 of my vitae —— actually, page 51 of
`
`Exhibit 1005.
`
`Q
`
`I see that you list a number of companies.
`
`Have you been an expert witness for any of those
`
`companies in litigations?
`
`A
`
`You compare this list to the list that I
`
`list in my litigations, you see that none of them
`
`have been involved in litigation.
`
`Q
`
`Professor,
`
`the listing in section V is
`
`confined to patent cases, and my question is not
`
`confined to patent cases.
`
`So there are many other kinds of cases
`
`besides patents.
`
`A
`
`Q
`
`A
`
`You're talking about
`
`in general
`
`legal?
`
`Yes.
`
`NO.
`
`
`
`
`
`
`
`
`Q
`Okay.
`L. J
`Ven'text Chicago Reporting Company
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`847—406-3200
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`l
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`Page 21
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`A
`
`My only consulting to companies related to
`
`legal matters has been the litigation cases that I
`
`list in page 2 of my resume or page 52 of 1005,
`which was accurate as of the writing of that time.
`
`It excludes the present case.
`
`Q
`
`Have you had any direct discussions with
`
`CMO, CMI,
`
`Innolux, Acer, ViewSonic, Vizio,
`
`Westinghouse about this case?
`
`A
`
`Q
`
`About this case? No.
`
`And when I say "this case," I mean these
`
`proceedings at the patent office, as well as the
`
`district court litigation.
`
`A
`
`Q
`
`Again, related to this case, no.
`
`I‘m going to show you several pages, but
`
`before I mark,
`
`I just wanted to know if these are
`
`all related to one another.
`
`If they are,
`
`I'm going
`
`to mark them as a single exhibit.
`
`I'll staple them together if they are from
`
`a single place.
`
`A
`
`These are pages from our laboratory Web
`
`page.
`
`I
`
`MR. MANZO: Okay.
`
`Let me make that a
`
`single exhibit, which I'll staple together, as
`
`Exhibit 2008.
`
`MR. MURPHY:
`
`You said 2008?
`
`
`
`
`
`312-442—9087
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`Veritext Chicago Reporting Company
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`
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`
`
`MR. MANZO: Yes.
`
`I believe that's the next
`
`Page 22
`
`
`
`number.
`
`(Deposition Exhibit 2008 was marked
`
`for identification by the court
`
`reporter and is attached hereto.)
`
`BY MR. MANZO:
`
`Q
`
`So your answer is that Exhibit 2008 comes
`
`from the website for the Display Research Lab;
`
`is
`
`that correct?
`
`A
`
`Q
`
`Yes, it appears so.
`
`And that's a picture of you on the very
`
`first page at the top, correct?
`
`A
`
`Q
`
`A
`
`Q
`
`From a long time ago.
`
`It looks much the same.
`
`Thank you.
`
`And these next
`
`two pictures of doctoral
`
`candidates of yours —— or, sorry.
`
`The first one is a doctoral candidate and
`
`the next one is a master's candidate;
`
`is that right?
`
`A
`
`Our website is a bit outdated.
`
`The master
`
`student is also a doctoral candidate right now, and
`
`there is another student that has been hired, and
`
`there is a post doc also.
`
`Q
`
`Look at the last sheet, please. There are
`
`
`
`some wave forms.
`
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`Do you see that?
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`A
`
`These are IV characteristics. We call them
`
`IV characteristics.
`
`Q
`
`Okay.
`
`I just wanted to identify the page.
`
`And then I want
`
`to actually look at the page right
`
`before that one,
`
`the one that starts out,
`
`"Polysilicon TFT on Steel."
`
`Do you see that?
`
`Yes.
`
`Professor,
`
`the first drawing there is a
`
`A
`
`Q
`
`sectional representation;
`
`is that right?
`
`A
`
`It is a cross section, a representation,
`
`correct.
`
`Q
`
`And the top layer is labeled as "Metal—l";
`
`is that right?
`
`A
`
`Q
`
`A
`
`Q
`
`That‘s correct.
`
`It sits on top of passivation oxide?
`
`That is correct.
`
`And I see that there is a transistor shown;
`
`is that right?
`
`A
`
`Q
`
`That is correct.
`
`The transistor has source and drain
`
`regions;
`
`is that right?
`
`A
`
`Q
`
`That is correct.
`
`How is metal~l connected, if at all,
`
`to the
`
`
`
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`Page 24
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`source or drain regions?
`
`A Well,
`
`in this particular device structure,
`
`after we form the source drain and gate regions of
`
`the transistor,
`
`the whole device is -— structure is
`
`covered by an oxide, which is labeled as passivation
`
`oxide.
`
`Then there is a lithographic step that is
`
`define contact holes,
`
`followed by an etching step
`
`that opens and removes —— open the contact holes and
`
`removes the passivation oxide above the source and
`
`drain regions.
`
`Then there is a deposition step that lays
`
`down the metal—l
`
`throughout the substrate,
`
`followed
`
`by a lithographic step that defines the regions
`
`where the metal remains.
`
`And upon completion of the etching step, we
`
`form what‘s known as a source and drain electrode.
`
`This is the metal—l regions that are attaching the
`
`source and drain regions of the device.
`
`Q
`
`So does the metal—l extend through the
`
`opening,
`
`the contact hole that you talked about,
`
`to
`
`reach the source and to reach the drain region?
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS:
`
`The metal—l conformily coats
`
`
`
`
`
`the walls of the holes and the bottom of the contact
`
`
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`312—442—9087
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`Page 25
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`hole and establish a region between the two vertical
`
`walls of the opening where the metal—l and the
`
`source or the drain is in direct contact.
`
`BY MR. MANZO:
`
`Q
`
`Does metal—l contact
`
`the source region or
`
`the drain region through the contact hole?
`
`A
`
`The metal goes down the metal hole and
`
`makes a contact to the source and drain region.
`
`Q
`
`Is that referred to as contact through a
`
`contact hole in the semiconductor industry,
`
`Professor?
`
`MR. GIBSON: Objection;
`
`form.
`
`MR. MANZO: Strike that.
`
`Q
`
`Is that type of contact referred to as
`
`contact through an opening or through a contact hole
`
`in the semiconductor industry?
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS: There are many ways to
`
`express an opening in a contact hole, and sometimes
`
`we call contact hole, sometimes we call them
`
`opening, sometimes we call them via.
`
`The contact
`
`is
`
`considered many different ways.
`
`Through hole is one
`
`way to accurately depict whether you have the hole
`
`open directly above —— the hole has been open
`
`
`
`
`
`through the layer that is deposited in between the
`
`
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`312—442—9087
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`Veritext Chicago Reporting Company
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`Page 26
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`two layers that you want to make a contact.
`
`80 in the cases where you have an
`
`intermediate insulating layer and you need to open a
`
`contact hole or the via or form some sort of an
`
`opening in the insulating layer,
`
`then the metal goes
`
`and covers conformily the hole.
`
`It has to cover
`
`conformily the edges of the hole, otherwise there
`
`will be a discontinuity. And even though you may
`
`have a metal on top of the passivation and you have
`
`a metal in the bottom of the opening, it is not
`
`covering the walls of the hole, you will not be able
`
`to maintain electro continuity of the metal.
`
`BY MR. MANZO:
`
`Q
`
`When you use the word "conform," what do
`
`you mean?
`
`A
`
`That there is —— as illustrated here in the
`
`schematic,
`
`that the metal coats the wall of the hole
`
`or the opening,
`
`so then there is a continuity of the
`
`metal from the upper surface of the oxide to the
`
`bottom of the opening.
`
`Q
`
`In your interactions with people, namely,
`
`engineers and the like, during your consulting with
`
`any of the companies you listed on page 51 of your
`
`declaration, namely,
`
`IBM, Kodak, et cetera, did you
`
`
`
`
`
`ever discuss circuit design with the people there?
`
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`Page 27
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`A
`
`Q
`
`Yes, we did.
`
`So is there a shorthand way in the
`
`semiconductor industry that you are aware of for
`
`this type of contact in a semiconductor circuit?
`
`A Well, when we are talking about a device
`
`structure, and there are many different ways to
`
`fabricate a device structure, we always list the
`
`sequence of the layers. We describe the device
`
`structure and we list the materials and we list the
`
`order with which the materials are laid down. And
`
`we have a very specific description of the device
`
`structure of how it is made and what is —— in what
`
`order the different steps are performed and what
`
`order the different layers and materials are put
`
`down.
`
`So within that context, words that you
`
`mentioned,
`
`like through hole, get a specific meaning
`
`and been understood by the experts in the field what
`
`they mean or ordinary skilled in the art of what
`
`they mean.
`
`Q
`
`So if one of your students working in the
`
`Display Research Laboratory or an engineer at one of
`
`these companies with whom you've consulted use the
`
`phrase “contact through an opening in an insulation
`
`
`
`
`
`layer," would you understand what
`
`
`they were talking
`
`
`312-442—9087
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`Page 28
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`about?
`
`A4
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`If they give me the structures —~ and even
`
`in this particular device structure that you're
`
`referring here, we have two different —— actually,
`
`we have more than one metal layer. What is shown in
`
`this particular structure is something called
`
`metal—l.
`
`In our design we have another layer which
`
`we call it metal—0. And the metal—O goes directly
`
`on top of the gate, and then there is a passivation
`
`oxide on top of it.
`
`So in that case when we opening the contact
`
`holes, we can reveal that layer, namely,
`
`the metal—O
`
`below the passivation oxide.
`
`So when we're referring to a structure, it
`
`is helpful to understand the sequence of the layers
`
`put down so we can understand what we mean by the
`
`word.
`
`Q
`
`Okay. Well,
`
`taking this structure in this
`
`figure in this Exhibit 2008, which is before you,
`
`does metal—l contact the source region through the
`
`contact hole?
`
`A
`
`The metal—l contacts the source through
`
`hole.
`
`
`
`
`
`And metal~l also contacts the drain region
`Q
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`312-442—9087
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`Page 29
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`through a different contact hole;
`
`is that right?
`
`A Metal—1 is making contact through hole to
`
`drain.
`
`Q
`
`How do people skilled in the art refer to
`
`those holes? What words do they use?
`
`I think you
`
`mentioned a few.
`
`You said "hole" or "through hole"
`
`and "via";
`
`is that right?
`
`A
`
`The openings can be called vias, it can be
`
`called contacts, it can be contact holes, it can be
`
`called cuts.
`
`Q
`
`A
`
`Cut?
`
`Cut.
`
`For example,
`
`in our process,
`
`the metal—l
`
`goes to the edge of the substrate and then it is
`
`covered by another passivation layer,
`so that
`passivation layer is covering the metal—l completely
`
`and we cannot make electrical contact because it is
`
`protected by another passivation layer.
`
`And we defined regions on top of those
`
`metal regions which we call those metal regions
`
`pads —- p-a—d—s, pads. And we're removing the
`
`second passivation oxide from those pads —— from
`
`above the pads, and we call that glass cut. Glass
`
`is the name for the final passivation layer.
`
`
`
`
`
`So the meaning or the name of those holes,
`
`
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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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`Page 30
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`there are several.
`
`Q
`
`I see. You said "glass cut," if I'm not
`
`mistaken?
`
`A
`
`Q
`
`A
`
`That's how we call it, yes.
`
`Good.
`
`That's the name of the mask layer we use to
`
`define those openings.
`
`Q
`
`How many people work at the digital
`
`research laboratory?
`
`A
`
`Q
`
`You mean the Display Research Laboratory?
`
`I apologize. You're right.
`
`I do mean the
`
`Display Research Laboratory.
`
`A
`
`Q
`
`A
`
`How many people work as of now or ~—
`
`Yes.
`
`~~ how many people went
`
`through and
`
`completed their degrees through their Ph.D.s?
`
`Q
`
`Let's say today.
`
`I mean, currently.
`
`I
`
`don't mean today, July 1, but these days.
`
`A
`
`My group, as I mentioned, right now
`
`consists of three graduate students,
`
`two
`
`undergraduate students, one post doc and one
`
`research engineer.
`
`They spent
`
`intermediate times
`
`through the laboratory.
`
`Q
`
`I'm sorry.
`
`I lost you-
`
`You said one
`
`
`
`
`
`research what?
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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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`A
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`Q
`
`A
`
`Engineer.
`
`Okay.
`
`He is a lab manager who takes care of some
`
`of the processing equipment and performs some of the
`
`processing steps in the more sophisticated equipment
`
`in the lab.
`
`Q
`
`Does the Display Research Laboratory
`
`conduct research for industry —— strike that.
`
`Does the research laboratory receive
`
`assignments from industry and execute research in
`
`response to those assignments?
`
`A
`
`We receive funding from industry.
`
`Some of
`
`the funding comes in the form of sponsor research
`
`programs.
`
`The sponsor research programs include
`
`what you refer to as assignments, but it is not
`
`specific assignments.
`
`As we define the research
`
`area and whether that would be some new material or
`
`some new device structures, and we investigate that
`
`area.
`
`And in other times we receive funding in
`
`the forms of research gifts, which are money that we
`
`receive, but that don't have a specific deliverable
`
`assigned to it.
`
`Q
`
`Professor, you have many published papers,
`
`yes?
`
`
`
`
`
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`312-442—9087
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`Veritext Chicago Reporting Company
`800—248—3290
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`Page 32
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`A
`
`I have a number of it.
`
`Q More than a hundred journal papers and
`
`conference papers?
`
`A
`
`Q
`
`A
`
`Q
`
`I
`
`think it is more than 150, but, yeah.
`
`Okay.
`
`But it's not a world record.
`
`Understood.
`
`How about patents, do you have any patents
`
`in your name?
`
`A
`
`Yes,
`
`I have a patent that was issued this
`
`spring.
`
`Q What is it about?
`
`A
`
`It is about a way to drive a new type of
`
`active metrics display called active metrics organic
`
`light—emitting diod
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