SEL EXHIBIT 2023
`
`INNOLUX CORPORATION v. PATENT OF SEMICONDUCTOR ENERGY
`
`LABORATORY CO., LTD.
`
`lPR2013-00066
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`
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`INNOLUX CORPORATION v. PATENT OF SEMICONDUCTOR ENERGY
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`LABORATORY CO., LTD.
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`lPR2013-00066
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`Page 1
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`UNITED STATES PATENT AND
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`TRADEMARK OFFICE
`
`BEFORE THE PATENT TRAIL AND APPEAL BOARD
`
`INNOLUX CORPORATION,
`
`Petitioner,
`
`vs.
`
`PATENT OF SEMICONDUCTOR
`
`:ENERGY LABORATORY CO., LTD.,
`
`Patent Owner.
`
`No.
`
`IPR2013-00068
`
`Patent 8,068,204
`
`VIDEOTAPED DEPOSITION OF MILTIADIS HATALIS, PH.D.
`
`Irvine, California
`
`Tuesday, July 2, 2013
`
`Volume I
`
`Reported by:
`
`DENISE BARDSLEY
`CSR NO. 11241
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`Job No. 1683385
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`PAGES 1
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`— 153
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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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`INNOLUX CORPORATION,
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`Petitioner,
`
`VS.
`
`)NO.
`
`IPR2013—00068
`
`)Patent 8,068,204
`
`)
`
`) )
`
`) )
`
`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
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`3 Park Plaza, Suite 1100, Irvine, California,
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`beginning at 9:14 a.m. and ending at 5:44 p.m. on
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`Tuesday, July 2, 2013, before DENISE BARDSLEY,
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`Certified Shorthand Reporter No. 11241.
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`Page 3
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`APPEARANCES:
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`For Petitioner:
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`JEFFER MANGELS BUTLER & MITCHELL LLP
`
`BY:
`
`STANLEY M. GIBSON
`
`Attorney at Law
`
`3 Park Plaza, Suite 1100
`
`Irvine, California
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`92614
`
`(949)
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`623—7200
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`sgibson@jmbm.com
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`For The Patent Owner:
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`STEPTOE & JOHNSON LLP
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`BY:
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`STANLEY A. SCHLITTER
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`Attorney at Law
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`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):
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`For The Patent Owner:
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`HUSCH BLACKWELL, LLP
`
`BY:
`
`EDWARD D. MANZO
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`BY:
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`MARK J. MURPHY
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`Attorneys at Law
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`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
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`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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`Videographers:
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`SCOTT SLATER, VERITEXT
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`CONRAD SZULADZINSKI, VERITEXT
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`INDEX
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`WITNESS
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`MILTIADIS HATALIS, PH.D.
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`VOLUME I
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`BY MR. MANZO
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`EXHIBITS
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`(NONE)
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`Page 5
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`EXAMINATION
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`Irvine, California, Tuesday, July 2, 2013
`
`9:14 a.m.
`
`THE VIDEOGRAPHER: Good morning.
`
`We are on the record at 9:14 a.m. on July
`
`09:14:45
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`2nd, 2013. This is the video—recorded deposition of
`
`Dr. Milt Hatalis. My name is Scott Slater, here
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`with our court reporter, Denise Bardsley.
`
`We are here from Veritext Legal Solutions
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`at the request of counsel for the patent owner.
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`09:15:07
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`This deposition is being held at 3 Park Plaza, Suite
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`1100,
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`in Irvine, California 92614.
`
`The caption of
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`this case is Innolux Corporation versus Patent of
`
`Semiconductor Energy Laboratory Co., Ltd., Case
`
`NO.
`
`IPR20l3—00068, Patent 8,068,204.
`
`09:15:34
`
`Please note that audio and video recording
`
`will take place unless all parties agree to go off
`
`the record.
`
`The microphones are sensitive and may
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`pick up whispers, private conversations or cellular
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`interference.
`
`I am not authorized to administer an
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`09:15:57
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`oath,
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`I am not related to any party in this action,
`
`nor am I financially interested in the outcome in
`
`any way.
`
`May I please have an agreement from all
`
`
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`parties that we may proceed?
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`09:16:08
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`Page 7
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`MR. MANZO:
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`So agreed.
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`MR. GIBSON:
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`I agree.
`
`THE VIDEOGRAPHER:
`
`Thank you.
`
`At this time will Counsel and all present
`
`please identify themselves for the record.
`
`09:16:17
`
`MR. MANZO:
`
`I'm Edward Manzo for the patent
`
`owner,
`
`from the firm —— law firm of Husch Blackwell,
`
`LLP. With me is my partner, Mark Murphy,
`
`from the
`
`same firm, and also with us is ~—
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`MR. SCHLITTER:
`
`Stan Schlitter from Steptoe
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`09:16:38
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`& Johnson, also for the patent owner.
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`MR. GIBSON: Stan Gibson on behalf of the
`
`petitioner.
`
`THE VIDEOGRAPHER:
`
`Thank you very much.
`
`Will
`
`the court reporter please administer the oath.
`
`09:16:47
`
`MILTIADIS HATALIS, PH.D.,
`
`having been administered an oath, was examined and
`
`testified as follows:
`
`EXAMINATION
`
`BY MR. MANZO:
`
`Q
`
`A
`
`Good morning, Professor.
`
`Good morning.
`
`
`
`
`
`Q
`I am placing before you a copy of the Shiba
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`09:17:11
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`Page 8
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`reference, which was marked as Exhibit 1003
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`previously, and it bears Patent No. 5,684,555.
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`Is it okay with you if we just refer to
`
`that as Shiba in these proceedings?
`
`A
`
`Q
`
`That will be fine.
`
`09:17:40
`
`Now, before we dig into the examination, we
`
`asked you a lot of questions yesterday morning about
`
`your background, and we're hoping that we don't need
`
`to repeat all those today and that we can rely on
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`yesterday's testimony with regard to your background
`
`09:18:29
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`and other examination on technical issues.
`
`Is that agreeable, Counsel?
`
`MR. GIBSON: His background is fine;
`
`I
`
`don't believe it's changed from yesterday to today.
`
`I'm not sure what you mean by rely on other
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`09:18:44
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`examination on technical issues. Certainly we don't
`
`need to cover his background again.
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`MR. SCHLITTER: We intend to use both the
`
`transcripts, probably,
`
`from yesterday and today and
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`both the '413 IPR and '204 IPR if that turns out to
`
`09:19:04
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`be appropriate. There are a lot of questions that
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`relate to the same exhibits in both ——
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`MR. GIBSON:
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`I don't disagree with that.
`
`I
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`just don't know what it means to use the same
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`
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`
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`technical understanding, so it is just too broad of
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`09:19:20
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`Page 9
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`a term.
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`If we have an objection to using something
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`in a different one,
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`then I don't know what that
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`would be. At this point I'd have to see how we are
`
`using it.
`
`I don't think we need to repeat questions
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`09:19:32
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`from yesterday.
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`MR. SCHLITTER: Okay.
`
`MR. MANZO:' Thank you.
`
`Professor ——
`
`Before we proceed, since you're not going
`
`09:19:41
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`Q
`
`A
`
`to be asking me any more questions about my
`
`background, may I make a comment related to some of
`
`the questions you asked me yesterday, for the
`
`record?
`
`Q
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`That's somewhat unusual.
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`09:19:59
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`What are they? Technical issues?
`
`A
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`No, no.
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`They are related to my experience
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`in patent litigation.
`
`You asked me a lot of
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`questions in those areas and you asked me,
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`percentagewise, about the income I received from
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`09:20:16
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`patent litigations and so on.
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`Q
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`A
`
`Q
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`Sure. Why don't you go ahead.
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`So ——
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`'Let me ask you a question.
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`
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`09:20:27
`Could you please clarify some of the issues
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`that were raised yesterday that you thought about
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`further overnight regarding your background.
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`A
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`Sure.
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`Thank you.
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`You asked me a lot of questions about my
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`litigation experience against —— a series of case
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`09:20:40
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`against SEL, and you also asked me a lot of
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`questions related to, percentagewise,
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`the income I
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`received from patent litigation work. And I was
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`going to make a comment that compared to the experts
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`that wrote the two response —— the two expert
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`09:21:03
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`reports for the last two patents that I was
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`involved,
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`I find out that I have less litigation
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`cases than them and that their rates are
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`significantly higher than mine.
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`So I just want to clarify,
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`that case,
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`that
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`09:21:24
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`some of them also work for more than one case,
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`several cases on behalf of SEL.
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`You comment that I worked against SEL,
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`that's because some of my clients were being sued ——
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`not my clients, but some of the law firms were being
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`09:21:42
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`sued by SEL, so I represented defendants in this
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`case, or in some case. And the other experts
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`represented SEL against some of the same clients.
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`So my litigation experience and my income
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`09:22:03
`than the other experts.
`is less than what it is,
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`Q
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`A
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`Q
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`I see.
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`Thank you.
`
`Thank you.
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`Professor,
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`I'm placing before you a copy,
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`also, of Exhibit 1001, which is the patent involved
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`09:22:26
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`in this inter partes review, Hirakata U.S. Patent
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`8,068,204.
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`Are you familiar with that patent?
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`Yes.
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`And I'm also placing before you a copy of
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`09:22:49
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`A
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`Q
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`the declaration that was filed as Exhibit 1007 in
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`this case.
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`Could you look at that Exhibit 1007 and see
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`if that's the declaration that you signed?
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`A
`
`Q
`
`Yes, it is.
`
`Could you please tell me if —— I'd like to
`
`know how this declaration was prepared. And so my
`
`first question is: Did you do the search for prior
`
`art that you applied in this patent —— in this
`
`declaration?
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`A
`
`Q
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`No,
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`I did not.
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`How did you come to cite these particular
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`references?
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`A
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`I was provided, by the counsel,
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`some prior
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`art references, and I selected the most relevant for
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`this particular content.
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`Q
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`Did you begin by reading the patent in
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`question, Hirakata, Exhibit 1001?
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`A
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`Of course.
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`I read '204,
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`I tried to
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`understand what
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`'204 —— what is the subject matter
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`09:24:53
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`of
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`'204, what is the objective of
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`'204, what are the
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`specifications and the claims of
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`'204, and then I
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`reviewed the pieces of prior art that I was provided
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`and selected the ones I thought was the most
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`relevant from that pool.
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`09:25:16
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`Q
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`And your selection was based on the claims
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`at issue;
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`is that right?
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`A Correct.
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`inn,
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`Q
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`A
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`How did you prepare for today's deposition?
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`I reviewed my declaration,
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`I reviewed the
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`09:25:51
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`petition for the inter partes review,
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`I reviewed the
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`board decision,
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`I reviewed the initial response of
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`the patent owner,
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`I also reviewed the request for
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`rehearing by the patent owners,
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`the decision of the
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`board on the rehearing request and, of course,
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`I
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`09:26:21
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`review the '204 patent and the three patents that
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`are cited in my declaration and which were accepted
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`by the board as a basis for these hearings and the
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`patent by Shiba,
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`the patent by Sukegawa and the
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`
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`patent by Watanabe.
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`09:26:48
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`I don‘t remember the exact patent numbers.
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`If you want,
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`I can refer to.
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`Q
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`A
`
`Q
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`NO.
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`It is referred to in my declaration.
`
`That's fine.
`
`09:26:59
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`And you met with your counsel for four
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`days —— I'm sorry.
`
`You met with counsel for
`
`petitioner for four days in preparing for these two
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`days of depositions?
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`A Correct.
`
`09:27{15
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`Q
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`In those four days did you cover both
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`patents or did you have four days for each patent?
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`Four days for the one and four more days for the
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`other one?
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`A
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`No, we covered both, and we did not work
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`09:27:27
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`full time because two of those days were the
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`weekend.
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`Q
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`Let me start with the Shiba reference,
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`which I think is the one you relied on primarily;
`
`is
`
`that correct?
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`09:28:00
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`A Correct.
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`The Shiba, Sukegawa and Watanabe.
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`Q
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`Does Shiba have an objective or desire to
`
`maximize the display area relative to the outside
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`dimensions of the panel?
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`
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`
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`Yes, it does.
`A
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`09:28:49
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`Q
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`Can you explain how Shiba goes about
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`achieving that objective, briefly?
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`A
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`One of the issues in making a panel —— one
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`of the steps in making a panel is the part that
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`assembles and seals the two counter substrates in an
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`09:29:20
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`area which is referred to as the seal area, and that
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`area occupies —— is all around the display and has a
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`certain width along the transverse direction of the
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`seal that is a distance that a lot of people tried
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`to minimize because the whole seal area is kind of a
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`09:29:52
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`wasted area.
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`It is needed in order to seal the
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`liquid crystal within, but it doesn't serve any
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`other purpose.
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`If one tried to make a seal very narrow,
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`there are problems that the seal is not very
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`09:30:15
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`effective.
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`If you make it very wide, you waste more
`
`area for that one.
`
`So the wiring that Shiba is proposing
`
`enables the user from a narrower sealant. That's
`
`one of the objectives in Sukegawa —— sorry —— in
`
`09:30:46
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`Shiba, and that's one of the approaches that he's
`
`taking.
`
`And another approach that he‘s taking,
`
`to
`
`reduce the dimensions of the panel.
`
`
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`And here I like to make a comment, since
`
`09:31:10
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`you were combining the proceedings from yesterday
`
`and today,
`
`that yesterday I was making a lot of
`
`statements about the —— that someone skilled in the
`
`art would know that minimizing the waste area and
`
`trying to make as much as possible of the display
`
`09:31:28
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`area relative to the size of the glass is very
`
`relevant.
`
`As you see here, it was an issue that was
`
`well known and a lot of researches attempted to
`
`maximize the size of the display relative to the
`
`09:31:50
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`size of the glass that's used to make that display.
`
`So the other —— continuing for Shiba is the
`
`other approach that Shiba is introducing is means to
`
`provide signals to the display only from two sides
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`and relative to prior art that were providing
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`09:32:24
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`signals from four sides or three sides, and that
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`would require more bonding area for pads and so on
`
`in these other sides.
`
`So by having two sides,
`
`that's an improvement.
`
`And in order to access the pads, which are
`
`away from the areas,
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`from the terminal regions from
`
`the pad areas that receive the signals and the power
`
`from the outside circuit board, Shiba is proposing a
`
`specific wiring that will have benefits of reduced
`
`09:32:40
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`resistance and improved manufacturing yield by
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`09:33:15
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`Page 16
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`eliminating manufacturing defects,
`
`in essence by
`
`having a two—layer wiring structure.
`
`And there may be other things.
`
`If you
`
`want,
`
`I can read more to Shiba and give you a bit of
`
`a summary.
`
`From the top of my head,
`
`I can refer to
`
`09:33:36
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`Shiba and give you more detail if I missed
`
`something, but ——
`
`Q
`
`Let me ask some more specific questions.
`
`Does Shiba aim to reduce the width of the
`
`seal region without
`
`lowering the strength of
`
`09:33:51
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`adhesion between the two substrates?
`
`A
`
`That is correct, by creating a wiring in a
`
`specific way that will have more surface contact
`
`area with the sealant, one can reduce the width of
`
`the sealant, while still maintain the strength of
`
`09:34:14
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`adhesion between the two substrates.
`
`Q
`
`And, finally, does Shiba also declare that
`
`his or her invention does not increase the number of
`
`manufacturing steps?
`
`A
`
`Q
`
`That is correct.
`
`09:34:42
`
`Let me invite your attention to Figure 3.
`
`And, as I see it, Figure 3 has a lower
`
`portion and an upper portion. Does that
`
`characterization seem reasonable to you?
`
`
`
`
`
`I can follow you.
`A
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`09:35:19
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`Q
`
`Okay.
`
`So what, generally,
`
`is the lower
`
`portion of Figure 3?
`
`A
`
`The lower portion is the external flexible
`
`wiring that comes and attaches to the glass, and the
`
`two pieces make contact in the terminal regions
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`09:35:38
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`where you have the pads via anisotropic conducting
`
`field.
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`Q
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`So you referred to two pieces.
`
`Is the
`
`first piece the lower part and the second piece the
`
`upper part?
`
`09:36:35
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`A
`
`The upper part is the glass substrate that
`
`contains the display area,
`
`the wiring,
`
`the seal,
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`the
`
`counter substrates.
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`Of course, not everything is shown at this
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`level of details, but I can refer to the exact
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`09:36:55
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`Watanabe is calling the elements.
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`Q
`
`A
`
`I don't need that.
`
`Okay.
`
`It isn‘t called the array substrate,
`
`it's the glass substrate.
`
`Q
`
`Okay.
`
`So where is the display region of
`
`this LCD depicted in Figure 3?
`
`A
`
`The display region is within the seal area.
`
`The seal area is element 111, 111.
`
`Q
`
`Do you mean that the display area is within
`
`09:37:16
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`the region circumscribed by the seal area 111?
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`A
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`No,
`
`I mean it is inside.
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`111 is two lines.
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`It's run parallel like a
`
`band. And within that band, over here,
`
`the upper
`
`left corner is the start of the display.
`
`It is the
`
`display surrounded by the 111 band.
`
`09:38:23
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`Q
`
`A
`
`Yes.
`
`So it is inside.
`
`It extends beyond the inside line of 111.
`
`Q
`
`And relative to what's been marked as X1,
`
`X2, X3, X4 and X5, where is the display area?
`
`09:38:41
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`A
`
`X1 is the first signal lines, data signal
`
`lines, also referred to as data lines.
`
`So X1, X2,
`
`X3, X4 is the first data lines of the array. And
`
`there may be hundreds of such lines, which it starts
`
`from the X1, and then you put one next to each other
`
`09:39:25
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`at specific interval, which is determined by the
`
`spacing between pixels. And depending upon the form
`
`of the display and how many lines you have, you have
`
`640 of such lines if it's a VGA, monochrome, 640
`
`times three if it is VGA color, and so on.
`
`09:39:50
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`Q
`
`A
`
`And so ——
`
`And then these are the data signal lines.
`
`And you also have the scanning lines.
`
`The scanning
`
`lines are orthogonal to the data lines.
`
`They start
`
`
`
`
`
`The 201d is
`from the opposing side of the display.
`
`
`09:40:20
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`Page 19
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`one of the shOrt sides of the display.
`
`The opposing
`
`side of that one is at 201C, so the scanning lines
`
`start from that side and they propagate orthogonal
`
`to the X lines, which are the data lines. And
`
`either the first or the last is the one that
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`09:40:57
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`terminates right past X1.
`
`And the first one —— the first one,
`
`probably, it goes up to where that square label
`
`125a.
`
`Q
`
`A
`
`Q
`
`Okay.
`
`09:41:20
`
`Stops short of that one.
`
`Okay.
`
`Thank you.
`
`So if you looked at Figure 1, for example,
`
`together with Figure 3, it is fair to say that
`
`Figure 3 is the bottom left corner of Figure 1 in a
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`09:41:32
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`
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`blowup view?
`
`A
`
`In Figure 1 there is a rectangle drawn
`
`called A.
`
`So Figure 3 is a magnification of the
`
`content within that rectangle labeled A.
`
`Q
`
`Good.
`
`So the display area is up and to the
`
`right of Figure 3, generally speaking, yes?
`
`A
`
`Yes.
`
`It starts from this corner and
`
`propagates ——
`
`Q
`
`Okay.
`
`09:41:53
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`—— up and to the right.
`A
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`Q
`
`Now,
`
`in Figure 3
`
`is area 731 a power supply
`
`pad? That's that box off to the corner of the
`
`sealant region.
`
`Do you see it?
`
`Yes,
`
`I see it.
`
`09:42:34
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`Is that a power supply pad?
`
`It is the pad that provides the power to
`
`A
`
`Q
`
`A
`
`the counter substrate.
`
`It is referred in column 5,
`
`line 51, as the power supply pad 731.
`
`And what it does is it receive a signal
`
`09:43:24
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`from the common pad 751. And the common pad 751
`
`receives the power or the signal from the external
`
`wiring 711.
`
`And then that through wiring,
`
`that signal
`
`goes to 731, and then through a conductive means,
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`09:43:55
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`like an epoxy that contains conductive particles,
`
`731 is making contact to the counter substrate that
`
`will be bonded to the substrate that is shown to the
`
`glass substrate 201.
`
`The two substrates will be bonded through
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`09:44:34
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`the seal, but the seal is not conductive.
`
`The
`
`seal —— or the epoxy that will be placed on the pad
`
`731 is a conductive one, and that will provide the
`
`connection to the ITO layer that it covers the
`
`
`
`
`
`entire surface of the counter glass substrate, which
`
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`09:44:55
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`Page 21
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`is the counter electrode for the pixels.
`
`Q
`
`Thank you.
`
`Just generally speaking,
`
`in Figure 4,
`
`just
`
`below Figure 3,
`
`is the display region to the right
`
`and the terminal region to the left?
`
`09:45:43
`
`A
`
`Q
`
`A
`
`In that cross section?
`
`In that cross section, yes.
`
`Correct.
`
`The right,
`
`the left with respect
`
`what —— with respect to the seal, yes.
`
`Q
`
`I was talking about left and right with
`
`09:46:07
`
`respect to the page that's on, but that's also with
`
`respect to the seal.
`
`So to the left of the seal,
`
`somewhat to the
`
`left of the seal,
`
`is a terminal region, correct?
`
`A Outside, correct.
`
`09:46:23
`
`Q All right. That's outside. And to the
`
`right of the seal you'can call inside, and that's
`
`where the display region is?
`
`A Correct. That's where you have a specific
`
`gap between the two substrates, and the liquid
`
`09:46:34
`
`crystal is contained within.
`
`Q
`
`And the pad 731 that you testified about a
`
`little while ago is shown in Figure 4 about —— near
`
`the bottom about 1 inch from the left side.
`
`
`
`
`
`Do you see it?
`09:46:58
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`Q
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`I see it.
`
`And then above that there is a substance or
`
`a part 115.
`
`Is that the —— what
`
`the patent refers
`
`to as transfer material?
`
`I think you called it an
`
`epoxy that's conductive.
`
`09:47:16
`
`A
`
`Q
`
`Correct.
`
`So that transfers electrical potential to
`
`the counter substrate, which is part, it looks like,
`
`501;
`
`is that correct? Well,
`
`the counter substrate,
`
`whatever number it is.
`
`09:47:46
`
`A
`
`The whole concept is 500.
`
`501 is the glass
`
`substrate.
`
`On the counter substrate —— on the
`
`counter substrate you have the ITO layer.
`
`Q
`
`Okay.
`
`Now, going back to Figure 3,
`
`just to
`
`confirm a few small things,
`
`is pad 731 electrically
`
`09:48:31
`
`in common with the line 121 dash what
`
`looks like a 1
`
`or an I?
`
`A
`
`Q
`
`I think it is a 1.
`
`You think. Okay. Yes or no?
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS: What do you mean
`
`"electrically in common"?
`
`It is formed by the
`
`extent —— it is the same metal.
`
`It's form is a big
`
`rectangle in the pad 731, and then the metal
`
`09:48:54
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`
`
`They are all
`continues and forms that wiring 121.
`
`
`09:49:16
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`Page 23
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`pre—made by the same material. And that material is
`
`the material of the data lines.
`
`BY MR. MANZO:
`
`Q
`
`A
`
`Okay.
`
`Could be made with other material, but the
`
`09:49:29
`
`preferred embodiment, it is from the data lines, it
`
`is listed.
`
`Q
`
`A
`
`I'm sorry. You are looking for something?
`
`Looking at the material that is made,
`
`like
`
`in column 6,
`
`line 25, "In the case where TFTs of
`
`09:50:07
`
`bottom gate type are used as switching devices as in
`
`the above embodiment,
`
`the power supply pads 731 to
`
`738,
`
`the common pad 751,
`
`the third wiring lines,
`
`121—1 to l21~4,
`
`the inter—connecting pad 125a, and
`
`125b the second wiring lines 123—1 to 123—4, and the
`
`09:50:43
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`first wiring line 127 can be formed in the same step
`
`of forming the data lines Xi."
`
`So it is the same material. And the mask
`
`that is used has a big rectangle where it is labeled
`
`731, it has a narrow wiring line 121, and so on.
`
`So they are not different pieces,
`
`they are
`
`formed all from the same initial metal layer that
`
`was put and covered the entire substrate, at least
`
`the remaining metal that's left.
`
`09:51:14
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`25
`
`Q
`
`Okay.
`
`So I think that all I'm trying to
`
`09:51:38
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`say is that they are electrically in common.
`
`They
`
`could be part of the same layer, but not be
`
`connected, right, because of masking —— strike that.
`
`That's unclear.
`
`When a person puts down a layer of metal,
`
`09:52:05
`
`it is governed by the mask;
`
`is that right?
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS: Well, you put the metal and
`
`cover the entire substrate, and then you use a
`
`masking step followed by an etching step to the
`
`09:52:24
`
`regions of the metal to form the different elements.
`
`Some of those regions, such as the lines
`
`X1, X2, X3, X4,
`
`they are long continuous lines
`
`starting from the pad 761 and continue to the other
`
`end of the display and stopping short of the other
`
`09:52:53
`
`sealant, of the opposing side of the sealant.
`
`Other regions, such as the ones that I just
`
`quoted from the patent, namely, 731, 121, 751, 123,
`
`125 and 127,
`
`they are all continuous metals and just
`
`say different ways, but all part of one continuing
`
`09:53:29
`
`pattern that is connected.
`
`BY MR. MANZO:
`
`Q
`
`A
`
`Fine.
`
`It's —— there is no any discontinuity.
`
`
`
`From 751 you can go to all those regions and still
`
`
`09:53:52
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`Page 25
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`be on the same metal.
`
`And —~ so, for example, if 751 you put like
`
`5 volts in 751, you give it the potential of 5
`
`volts,
`
`then all that wiring in that pad will be held
`
`at 5 volts.
`
`09:54:30
`
`Q
`
`Okay.
`
`So if you put 5 volts on 751,
`
`there's also going to be 5 volts on 121—1 and 731
`
`and 123—1 and 127 and 125 —— well,
`
`I'm not sure
`
`about 125a —— strike 125a —— is that correct?
`
`A
`
`125a is also part of it.
`
`It is a square
`
`09:54:54
`
`piece of metal.
`
`Q
`
`A
`
`Okay.
`
`From Figure 3. And then there are other
`
`elements from Figure 1 that also will be at 5 volts.
`
`It will be the 732 —— well,
`
`the 732 receives —— but
`
`09:55:08
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`from 751 it will be 731, 735, 736, 737, 738,
`
`SO it
`
`will be multiple pads that will receive that signal.
`
`And it continues, also, on the other side.
`
`Q
`
`A
`
`Professor, where is 732 —— sorry?
`
`You see that in Figure 1.
`
`But I said strike that one because 732
`
`receives a signal from another pad, not the 751.
`
`Q
`
`A
`
`Okay.
`
`But the one from 751 goes to 731 and then
`
`09:55:43
`
`through the wiring 127 goes to 735, —36, —37, —38,
`
`09:55:59
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`and it continues and gets connected up to 734.
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`Q
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`A
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`Q
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`A
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`Q
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`A
`
`Pardon me. Where is 734?
`
`You can see that in Figure 1.
`
`I see.
`
`It's the lower right corner.
`
`09:56:30
`
`Thank you.
`
`The wiring 727 forms almost like a pi, a
`
`Greek pi letter and kind of surrounds the display
`
`starting from 751 back.
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`Q
`
`I'm not sure how it resembles the Greek
`
`09:57:12
`
`letter pi.
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`A
`
`It is like a P, it is like this,
`
`that and
`
`then that.
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`Q
`
`Oh, with regard to the —— I —— what you're
`
`'saying is that looking at Figure 1, which is a plan
`
`09:57:34
`
`View,
`
`the lines 127, if they start at the bottom
`
`left, rise upward and then traverse across to the
`
`right and then traverse downward?
`
`A Correct.
`
`Q
`
`And that's what the Greek letter pi
`
`09:57:52
`
`somewhat
`
`looks like?
`
`A
`
`Q
`
`Yes.
`
`Now,
`
`is it correct that lines 127 are not
`
`electrically in common with the data line pads shown
`
`in Figure 3 as 761, 762, 763 and 764?
`
`
`09:58:19
`
`
`
`312-442—9087
`
`Veritext Chicago Reporting Company
`800—248—3290
`
`847-406—3200
`
`
`
`
`
`Page 27
`
`MR. GIBSON: Objection;
`
`form.
`
`THE WITNESS: You are using —— you
`
`introduced new terminology, "electrically in
`
`common," which is not —— I'm not familiar with this
`
`term.
`
`BY MR. MANZO:
`
`09:58:40
`
`Q All right.
`
`Let me ——
`
`A Electrically connected or same potential?
`
`What do you mean? Touching?
`
`Q
`
`Let me ask you a broad, open—ended
`
`09:58:49
`
`question,
`
`then.
`
`A
`
`Q
`
`Okay.
`
`Is there a relationship between the power
`
`supply pad 731 and the data line pad 761, 2,
`
`3 and
`
`4?
`
`09:59:04
`
`A
`
`The common pad 751,
`
`that is connected, and,
`
`as we said earlier,
`
`the 5 volt in 751, it will be
`
`5 volt in 731. That is controlled by the external
`
`wiring, which is labeled 821a, which is the first
`
`external wiring from the element 711 from the lower
`
`part of —— the lower part —— not the Figure 4, say
`
`Figure 3,
`
`the wirings 821a,
`
`that‘s the wiring that
`
`provides the signal to common pad 751.
`
`Q
`
`Okay. And to the right of 821a there are
`
`09:59:32
`
`
`
`
`
`10
`
`ll
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`further lines?
`
`10:00:00
`
`
`
`Veritext Chicago Reporting Company
`800—248-3290
`
`312—442—9087
`
`847-406-3200
`
`
`
`
`
`Page 28
`
`A
`
`Right. Other pads.
`
`Each one connected to
`
`a data line, and they receive signal from the
`
`external wirings, other external wirings.
`
`If those
`
`external wirings happen to be the same voltage as
`
`the 751,
`
`then there may be —— one of the data wiring
`
`10:00:30
`
`may also be in the same voltage, but that's because
`
`the signal is received and happens to be in the same
`
`voltage.
`
`So if, for example,
`
`they all get 5 volts,
`
`5 volts will appear to all of them. Maybe the
`
`10:00:44
`
`5 volts only go to 751, and 761 get 1 volt, and 762
`get 2 volts,
`3 volts or 4 volts,
`they can all be
`
`separate, separate potentials,
`
`independently
`
`determined by the outside circuit.
`
`Q
`
`Okay.
`
`So it's fair to say that pad 751,
`
`10:01:02
`
`761 through 764 are five independent pads?
`
`A Correct.
`
`Q
`
`A
`
`Now ——
`
`There are four —— as we said,
`
`there will be
`
`hundreds of these pads. There will be four pads
`
`10:01:32
`
`that will have the same voltage as 751, and you will
`
`be able to see that in Figure 1.
`
`Q
`
`A
`
`I think you described those ——
`
`Okay.
`
`
`
`
`
`—— a little while ago.
`Q
`
`
`10:01:48
`
`312—442-9087
`
`Veritext Chicago Reporting Company
`800-248—3290
`
`847—406—3200
`
`10
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`11
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`Page 29
`
`A
`
`But all the other pads,
`
`they will be
`
`independent.
`
`Q
`
`Okay.
`
`Is the sealant marked as region 113
`
`in Figure 4?
`
`A
`
`Q
`
`sealant.
`
`A
`
`Q
`
`The sealant material ——
`
`10:02:11
`
`I just want to know the part number of the
`
`Yeah, 113 is the sealing material.
`
`And you mentioned that in your declaration
`
`at paragraph 48,
`
`I think.
`
`10:02:35
`
`Could you confirm that on page 15?
`
`A
`
`Yes.
`
`So 113 is the sealant material and
`
`111 is the seal region;
`
`in other words, what is the
`
`projection or the regions on Figure 3 where the
`
`sealant will be applied.
`
`Just clarify,
`
`the 111 and 113.
`
`Q
`
`Going back to 111,
`
`then,
`
`in Figure 3,
`
`some
`
`of the —— well,
`
`looking at the reference number
`
`111 —— do you see it?
`
`A
`
`Q
`
`Yes,
`
`the seal region.
`
`And just to the right of the number 111
`
`there are these lines marked in a bracket as 127?
`
`A Correct.
`
`Q
`
`Now,
`
`some of those are in solid lines and
`
`
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`10:03:04
`
`10:03:30
`
`some of those are in broken lines.
`
`10:03:43
`
`
`Veritext Chicago Reporting Company
`800—248—3290
`
`847-406—3200
`
`312—442—9087
`
`
`
`
`
`Page 30
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`
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`10
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`2O
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`21
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`22
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`23
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`24
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`25
`
`Why is that?
`
`A
`
`The ones that are in broken lines,
`
`they are
`
`considered to be under the sealant —— under the
`
`sealant.
`
`So they will be covered by the sealant
`
`material.
`
`So,
`
`in a way, if the sealant material is
`
`10:04:03
`
`opaque, you wouldn't be able to see them.
`
`So the
`
`artist kind of do them with broken lines to say that
`
`they will be there.
`
`Even if you look from the top
`
`of the glass, you won't be able to see them.
`
`If you
`
`look from the bottom side of the glass, you will be
`
`10:04:17
`
`able to see them.
`
`Q
`
`A
`
`And the
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