SEL EXHIBIT 2014
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`INNOLUX CORPORATION V. PATENT OF SEMICONDUCTOR ENERGY
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`LABORATORY CO., LTD.
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`|PR2013—OOO68
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`INNOLUX CORPORATION V. PATENT OF SEMICONDUCTOR ENERGY
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`LABORATORY CO., LTD.
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`|PR2013—OOO68
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`INNOLUX CORPORATION,
`
`Petitioner,
`
`vs.
`
`No.
`
`IPR2013—0OO60
`
`Patent 7,697,102
`
`PATENT
`
`OF SEMICONDUCTOR,
`
`ENERGY
`
`LABORATORY CO., LTD.,
`
`Patent Owner.
`
`VIDEOTAPED DEPOSITION OF MILTIADIS HATALIS,
`
`Ph.D.
`
`Irvine, California
`
`Friday, July 12, 2013
`
`Reported by:
`
`SHERRY
`
`A. CASE, RPR, CLR,
`
`CSR No.
`
`2989
`
`Job No.
`
`1683387
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`PAGES 1
`
`— 178
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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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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 2
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`INNOLUX CORPORATION,
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`Petitioner,
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`VS.
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`NO.
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`IPR20l3—OOO6O
`
`Pa
`
`tent 7,697,102
`
`PATENT OF SEMICONDUCTOR,
`
`ENERGY LABORATORY CO., LTD.,
`
`Patent Owner.
`
`Videotaped Deposition of
`
`MILTIADIS HATALIS, Ph.D.,
`
`taken on b
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`ehalf of Patent
`
`Owner,
`
`at 3 Park Plaza,
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`Suite 1100,
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`Irvine,
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`California,
`
`beginning at 9:03 a.m.,
`
`and ending at
`
`6:53 p.m.
`
`on Friday,
`
`July 12, 2013,
`
`before
`
`SHERRY A. CASE,
`
`Certified Shorthand
`
`Reporter
`
`NO. 2989,
`
`CLR, RPR.
`
`uh-(.~J[\J|—‘
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`APPEARANCES:
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`FOR THE PETITIONER:
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`Page 3
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`JEFFER MANGELS BUTLER & MITCHELL LLP
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`BY:
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`GREGORY S. CORDREY, ESQ.
`
`3 Park Plaza
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`Suite 1100
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`1rvine, CA 92614
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`949.623.7236
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`GCordrey@jmbm.com
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`STEPTOE & JOHNSON LLP
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`BY:
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`STANLEY A. SCHLITTER, ESQ.
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`DOUGLAS R. PETERSON, ESQ.
`
`115 South Lasalle Street
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`Suite 3100
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`Chicago,
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`IL
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`60603
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`312.577.1250
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`Ssch1itter@steptoe.com
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`Dpeterson@steptoe.com
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`Ahomier@steptoe.com
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`312-442-9087
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`Veritext Chicago Reporting Company
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`APPEARANCES (CONTINUED):
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`FOR THE PATENT OWNER:
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`Page 4
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`ROBINSON INTELLECTUAL PROPERTY LAW OFFICE
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`BY:
`
`SEAN FLOOD, ESQ.
`
`3975 Fair Ridge Drive
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`Suite T20 North
`
`Fairfax, VA
`
`22033
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`571i434.6789
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`Sf1ood@rip1o.com
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`Erobinson@rip1o.com
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`VIDEOGRAPHER:
`
`SCOTT SLATER
`
`VERITEXT LEGAL SOLUTIONS
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`I N D E X
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`Page 5
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`WITNESS: MILTIADIS HATALIS,
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`Ph.D.
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`EXAMINATION
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`BY MR.
`
`SCHLITTER:
`
`EXHIBIT
`
`DESCRIPTION
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`PAGE
`
`E X H I B I T S
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`Exhibit
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`1005
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`Exhibit CMI 1005 captioned
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`"Declaration of Miltiadis
`
`Hatalis, Ph.D."
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`Exhibit
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`1001
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`United States Patent
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`7697102 Hirakata previously
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`marked as CMI Exhibit 1001
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`Exhibit
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`1003
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`Previously been marked as
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`CMI Exhibit 1003, Shiba, et
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`al., United States Patent
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`NO. 5684555
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`Exhibit
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`2006
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`Enlarged version of
`
`76
`
`Figure 4 from the Shiba
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`reference
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`Exhibit
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`2007
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`Enlarged version of
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`Exhibit
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`1004
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`CMI Exhibit 1004
`
`Figure 3
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`118
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`172
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`Irvine, California; Friday, July 12, 2013
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`9:03 A.M.
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`Page 6
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`02
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`09:
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`THE VIDEO OPERATOR: Good morning.
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`We are on the record at 9:03 a.m. on July 12th,
`
`2013. This is the video—recorded deposition of
`
`Dr. Milt Hatalis.
`
`I'm Scott Slater, here with our court reporter,
`
`Sherry Case. 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,
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`in the City of Irvine, California 92614.
`
`The caption of this case is Innolux Corporation versus
`
`Patent of Semiconductor Energy Laboratory Co. dot ——
`
`or CO., LTD, Case NO.
`
`IPR 2013-00060, Patent 7697102.
`
`Please note that audio and video recording will
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`take place unless all parties agree to go off the
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`record.
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`The microphones are sensitive and may pick up
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`whispers, private conversations, or cellular
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`interference.
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`I am not authorized to administer an oath.
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`I
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`am not related to any party in this action, nor am I
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`financially interested in the outcome in any way.
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`May I please have an agreement from all parties
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`that we may proceed.
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`MR. SCHLITTER: We agree.
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`MR. CORDREY: Yes.
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`THE VIDEO OPERATOR:
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`Thank you.
`
`At this time, will counsel and all present
`
`please identify themselves for the record.
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`MR. SCHLITTER:
`
`Stan Schlitter and Doug
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`Peterson from Steptoe & Johnson for the patent owner,
`
`and also Sean Flood from Robinson & Marshall
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`Intellectual Property Office for the patent owner.
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`MR. CORDREY: Gregg Cordrey of Jeffer, Mangels,
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`Butler & Mitchell on behalf of the petitioner,
`
`Innolux
`
`Corporation.
`
`THE VIDEO OPERATOR:
`
`Thank you very much.
`
`Will the court reporter please administer the
`
`oath.
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`THE COURT REPORTER: You do solemnly swear that
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`the testimony you're about to give in the cause now
`
`pending to be the truth,
`
`the whole truth, and nothing
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`but
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`the truth.
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`THE WITNESS:
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`I do.
`
`MILTIADIS HATALIS, Ph.D.
`
`having been first administered an oath, was examined
`
`and testified as follows:
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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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`EXAMINATION
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`Page 8
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`BY MR. SCHLITTER:
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`Q
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`A
`
`Q
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`Good morning, Dr. Hatalis.
`
`Good morning.
`
`Since your deposition's been taken several
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`times before,
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`I will skip some of the preliminary
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`things about depositions,
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`but just remind you,
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`of
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`course, you're under oath and —— and obligated by law
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`to tell the truth to all the questions.
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`Do you understand that?
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`Yes.
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`And also,
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`if I ask a question that you do not
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`A
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`Q
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`understand, please let me know.
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`If you —— if you
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`don't let me know that, it will be assumed that you've
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`understood the question that I asked.
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`A
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`Q
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`Okay.
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`Did you do anything to prepare for your
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`deposition today?
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`A
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`I did.
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`Q What did you do?
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`A
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`I review my declaration.
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`I review the
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`petition.
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`I review the initial response, preliminary
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`response of the patent owner.
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`I review the decision
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`from ——
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`of
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`the board.
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`I review the relevant patent,
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`
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`the 'lO2 Patent, and the —— the prior art patent that
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`I list in my declaration, namely,
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`the Shiba patent and
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`the Moriyama patent.
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`Q
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`Did you review any other document
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`to prepare
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`for your deposition today?
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`A
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`I —— I review briefly the transcripts of the
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`last three depositions, particularly as —— as one of
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`them related to the Shiba.
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`The Shiba was a prior art in another recent
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`deposition of mine.
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`Q
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`A
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`Do you remember which deposition it was?
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`Was that 206?
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`It was...
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`MR. CORDREY:
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`204.
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`THE WITNESS:
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`204. Okay.
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`BY MR. SCHLITTER:
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`Q
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`A
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`Is that the only transcript you reviewed?
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`Recently.
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`A few weeks ago,
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`I review the —— the
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`transcripts for the first three depositions that
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`were —— were held in this room in May.
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`Q
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`A
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`Your depositions, you mean?
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`Right, my depositions in re to '480 and '978.
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`I didn't read those ones for today's
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`deposition.
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`And I also met with a —— with my counsel.
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`Q When did you meet?
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`A
`
`Q
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`The last two days.
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`Who specifically did you meet with?
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`A » Mr. Glenn Cordrey and his colleague,
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`Ali Shalchi.
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`Q
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`Other than reviewing those depositions and the
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`meeting you had for the last two days, did you do
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`anything else to prepare for your deposition today?
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`A
`
`Q
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`I —— I don't recall. No.
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`Okay.
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`I've put in front of you what was
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`previously marked as Exhibit CMI 1005 captioned
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`"Declaration of Miltiadis Hatalis, Ph.D."
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`Do you recognize this?
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`A
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`Yes. This is my declaration in support of the
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`petition for the Patent
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`‘I02.
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`(Exhibit 1005 was previously marked
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`for identification and is attached
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`hereto.)
`
`BY MR. SCHLITTER:
`
`Q
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`Referring to Appendix A, which is your
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`curriculum vitae,
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`is this accurate and up to date?
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`A More or less as of the time of —— of the
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`writing, which was in November.
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`Q
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`Was there a change you would make to update it
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`as of today?
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`A
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`There are some few additional papers and grants
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`that I received.
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`Q
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`Did any papers pertain to liquid crystal
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`displays?
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`A
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`They were related to isometric displays,
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`in
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`particular the active matrix organic light—emitting
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`diode displays.
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`And some of the papers are related to TFT,
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`to a
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`new TFT technology called IGZO, and this new
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`technology can be applied both to liquid crystal
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`displays as well as to active matrix or LED displays.
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`You had requested at the last deposition that
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`you took from me an updated vitae, and I have provided
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`that to my counsel, which is updated as of June 2013.
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`MR. SCHLITTER: Could you provide a copy to us,
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`please?
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`MR. CORDREY: Yeah.
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`MR. SCHLITTER: Okay.
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`BY MR. SCHLITTER:
`
`Q
`
`Is there anything else that you are aware of
`
`that should be added to update and make current your
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`curriculum vitae, Appendix A?
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`A
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`In addition to the scientific papers,
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`there is
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`a patent that has been issued in the spring that I'm a
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`co—inventor.
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`I also need to update in the patent
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`
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`litigation cases this case, regard this case.
`
`And in the area of —— of the grants,
`
`research
`
`funding, which is the -- the last section in mine,
`
`I
`
`receives two additional research gifts since the time
`
`that this vitae was prepared.
`
`Q Were any of the grants that you've received
`
`recently that are not listed on this Appendix A ones
`
`you received from industry?
`
`A
`
`They were all from industry.
`
`Q Were any of them from any company outside the
`
`United States?
`
`A
`
`NO.
`
`These are U.S.—based companies.
`
`Some of them
`
`may have international divisions, but
`
`they are
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`U.S.~based companies.
`
`One of them —— actually,
`
`that one,
`
`I think, was
`
`listed.
`
`One gift was from Supralaboratories of America,
`
`SLA. They're —— it's a U.S —based company.
`
`But
`
`the other company is Sharp in Japan.
`
`Q
`
`Did you read every word of this declaration
`
`before you signed it?
`
`A
`
`This is my declaration.
`
`Of course I read every
`
`word,
`
`to make sure there are not
`
`inaccuracy and stuff
`
`like that.
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`Page 13
`
`But I have also prepared this declaration.
`
`09:16
`
`Q What was the process that you went
`
`through to
`
`09:16
`
`prepare this declaration?
`
`09:16
`
`A
`
`I review the '102 Patent.
`
`I review prior art,
`
`09:16
`
`literature, namely, patents. And I received guidance
`
`09:16
`
`from the —— from the counsel related to the format and
`
`09:16
`
`the -— the process of preparing because this is a new
`
`09:17
`
`proceeding.
`
`By the time of
`
`'102,
`
`I have already prepared
`
`09:17
`
`09:17
`
`one or two.
`
`They may be not the sequence. This is
`
`09:17
`
`probably the third or the fourth in —— in a series of
`
`09:17
`
`five that I worked on in the fall of 2012.
`
`Q
`
`Did you do any prior art searching in
`
`connection with preparing this declaration?
`
`A
`
`I was provided with a folder of —— that
`
`included several pieces of —— of prior art, and I
`
`09:17
`
`09:17
`
`09:17
`
`09:17
`
`09:17
`
`became familiar with those pieces of prior art, and I
`
`09:17
`
`selected the ones most relevant to prepare this
`
`declaration.
`
`Q
`
`Who provided you that folder of prior art
`
`patents?
`
`A
`
`Q
`
`A
`
`The counselor, Oblon.
`
`Who specifically?
`
`Scott McHugh is the lead counsel.
`
`I ——
`
`I —-
`
`I worked with other attorneys at Oblon.
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`09:17
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`09:18
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`If my memory is correct,
`
`the
`
`‘lO2 involved also
`
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`14
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`Tom Fisher.
`
`Q
`
`Did you select
`
`any patent from that folder --
`
`let me start over.
`
`Did you select
`
`the Shiba reference from that
`
`folder?
`
`A
`
`Q
`
`folder?
`
`A
`
`Q
`
`folder?
`
`Yes.
`
`Did you select
`
`the Moriyama reference from that
`
`Yes.
`
`Did you select
`
`any other reference from that
`
`A
`
`I reviewed references from that folder here.
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`As
`
`I said, all them,
`
`those are ones that were selected
`
`in this final document.
`
`Q
`
`Have you had any prior experience with respect
`
`to the ‘lO2 Patent prior to your work in connection
`
`with preparing this declaration?
`
`A What do you mean by "prior experience"?
`
`Q
`
`A
`
`Q
`
`A
`
`Had you seen that patent before?
`
`I do not recall.
`
`I do not think so.
`
`Who prepared the first --
`
`Just to make sure that I am fully answer your
`
`questions,
`
`the —— when you said "prior," I would
`
`assume it is prior to the beginning of these five
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`15
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`declarations of mine, which means —— which means prior
`
`to the onset of these preparations, which means prior
`
`to,
`
`I guess, September of 2012.
`
`Before working on the '102 Patent,
`
`I worked on
`
`the '480 Patent, and the '102 and '480 share the same
`
`specifications.
`
`So right before '102,
`
`I became
`
`familiar with the '480.
`
`But prior to the September of 2012,
`
`I do not
`
`recall seeing these —— any of these patents.
`
`Q
`
`Who prepared the first draft of this
`
`declaration?
`
`A
`
`The outline,
`
`the format of what needs to be
`
`done,
`
`the different sections, because I've never done
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`this before.
`
`As I said,
`
`these are new proceedings,
`
`was provided by the Oblon.
`
`But
`
`the content
`
`in the different sections,
`
`these were my content.
`
`This is content that I
`
`provided.
`
`Q
`
`So I have handed you a copy of United States
`
`Patent 7697102, Hirakata, et al.
`
`It's marked
`
`previously as CMI Exhibit 1001.
`
`Is this the so—called '102 Patent you've been
`
`referring to?
`
`A
`
`Yes.
`
`(Exhibit 1001 was previously marked
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`Page 16
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`for identification by the court
`
`reporter and is attached hereto.)
`
`BY MR. SCHLITTER:
`
`Q
`
`Do you understand that this '102 Patent
`
`discloses first, second, and third internal conducting
`
`lines?
`
`A
`
`Q
`
`Yes.
`
`So, for example, Claim 15 refers to a first
`
`internal conducting line and a second internal.
`
`conducting line.
`
`What do those correspond to,
`
`in your opinion,
`
`in the '102 Patent?
`
`MR. CORDREY: Objection.
`
`Form.
`
`THE WITNESS:
`
`The '102 Patent is describing
`
`connections between an extractor terminal and the
`
`common contact portions, and there are four sets of
`
`common contact portions that provide a signal to the
`
`counter electrode.
`
`Starting from the extractor terminal ——
`
`BY MR. SCHLITTER:
`
`Q
`
`A
`
`Are you referring to a figure?
`
`Figure 13 is the common contact portions, and
`
`Figure 3 lists the four sets in common contact —— the
`
`presence of four sets contact —— common contact
`
`portions.
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`Q Where are the common contact portions shown in
`
`09:27
`
`Page 17
`
`Figure 3?
`
`A
`
`Q
`
`A
`
`These are the 206a, 206b, 206c, 206d.
`
`Are extractor terminals shown in Figure 3?
`
`The ones connected to the common Contact
`
`portions are the 205a and the 205b.
`
`V
`
`Q
`
`Are there other extractor terminals in
`
`Figure 3, other than 205a and 205b?
`
`A
`
`Yeah.
`
`There are a plurality of —— of...
`
`09:27
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`09:27
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`09:27
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`09:27
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`09:27
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`09:27
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`09:27
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`09:27
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`09:27
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`Q
`
`Do you understand that numeral 205 was a lead
`
`09:27
`
`line going to inside of a dashed line to encompass
`
`09:28
`
`extractor terminals,
`
`to identify extractor terminals?
`
`09:28
`
`A
`
`Give me one second, please.
`
`09:28
`
`There are many extractor terminals highlighted
`
`09:29
`
`or labeled as 205 that provide electric power and
`
`09:29
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`control signals from the outside to the various parts
`
`09:29
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`on the substrate 201, and those parts are the
`
`09:29
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`peripheral circuits that drive the display. These are
`
`09:29
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`the —— peripheral circuits are the 203 and 204.
`
`And two of those extractor terminals are
`
`09:30
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`09:30
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`connected and provide the power to the common contact
`
`09:30
`
`portions which I have identify a moment ago, 206a,
`
`c and d.
`
`09:30
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`09:30
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`Q
`
`Are the two extractor terminals that provide
`
`09:30
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`power to the common Contact portions labeled in
`
`Figure 3?
`
`A
`
`Q
`
`These are 205a and 205b.
`
`iAre 205a and 205b referred to in the '102
`
`Patent as common terminals?
`
`A
`
`That is correct.
`
`That is in Column 8, Line 15.
`
`It is
`
`electrically connected with common terminals 205a and
`
`205b, respectively.
`
`Let me read the whole quote.
`
`Column 8,
`
`Line 14, it reads,
`
`"The internal lines 207a and 207b
`
`extend to the extractor terminals 205
`
`Page 18
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`and are electrically connected with
`
`common terminals 205a and 205b,
`
`respectively."
`
`So the bigger question, of course, related to
`
`the first internal conducting line and the second
`
`internal conducting line. These are lines that are
`
`used in these internal lines 207a and 207b.
`
`Q
`
`If you look at Claim 15, one of the elements of
`
`Claim 15 reads as follows,
`
`"A first internal conducting line
`
`electrically connected to the common
`
`terminal
`
`in the contact hole wearing
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`Page 19
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`the first internal conducting line and
`
`a gate electrode of the thin—film
`
`transistor are created by a first
`
`processing step."
`
`Is the first internal conducting line shown in
`
`Figure 3?
`
`A
`
`It is the line 207C.
`
`And in Column 9, Line 61, it reads,
`
`"The internal conducting lines 207C
`
`and the gate electrode 307 were
`
`created by the same processing step."
`
`Q
`
`Referring again to Claim 15, another element of
`
`Claim 15 reads as follows,
`
`"A second internal conducting line and
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`a source electrode and a drain
`
`electrode of the thin—film transistor
`
`created by a second processing step."
`
`Is a second internal conducting line shown in
`
`Figure 3?
`
`A
`
`It is shown.
`
`Q Where is that shown?
`
`A
`
`Q
`
`For example,
`
`line 207a.
`
`Claim 39 includes the following element,
`
`"A third internal conducting line
`
`formed from a same layer as the source
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`Page 20
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`electrode and the drain electrode of
`
`the thin—film transistor,
`
`the third
`
`internal conducting line electrically
`
`connected to the first internal
`
`conducting line and the third internal
`
`conducting line electrically connected
`
`to the common terminal."
`
`Is a third internal conducting line shown in
`
`Figure 3?
`
`A
`
`Let me first complete my answer to your
`
`previous question and I will answer this question.
`
`Your previous question was is a second internal
`
`conducting line shown in Figure 3, and I answered it
`
`is shown.
`
`And you asked me where is that shown, and I
`
`gave you an example of line 207a.
`
`Within the context of the limitations described
`
`in Claim 15, another example of the second internal
`
`conducting line is the line 207b.
`
`So if we look at
`
`the Claim 15,
`
`there are two lines that meeting the
`
`limitations of the second internal conducting line.
`
`Turning to the latest question, related to
`
`Claim 39,
`
`in the third internal conducting line,
`
`the —— one of those two lines, namely, 207a or 207b,
`
`can be Viewed as the third internal conducting line.
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
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`
`
`
`So within the context of the Claim 39, one of
`
`the 207a and 207b is the third internal conducting
`
`line and the other is the second internal conducting
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`line.
`
`Q
`
`You identified terminals 205a and 205b as the
`
`common terminals, correct?
`
`A
`
`That is correct.
`
`Q What material are those terminals formed from
`
`in the 'lO2 Patent?
`
`A
`
`The claims refer to the common terminal as
`
`being formed from the same layer as the pixel
`
`electrode, but the common terminals 205a and 205b, as
`
`shown in Figure 3, are electrically connected to the
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`10
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`11’
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`wiring that leads to 206a and 206d, and that wiring --
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`since 207a and 207b, which we have identified them as
`
`the second internal conducting lines is made by the
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`same material as the drain electrodes and the source
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`electrodes,
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`the layer of the common terminal made by
`
`the pixel electrode material is connected to the layer
`
`of material made by the source and drain electrode.
`
`So the common terminal or the extractor
`
`terminal is the multi—layer structure.
`
`The upper
`
`layer, referred to as the common terminal,
`
`is made by
`
`the pixel electrode layer, whereas the lower layer is
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`made by the source and drain electrode layer.
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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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`
`
`In this particular embodiment.
`
`It could be
`
`made with another material as well.
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`It could be made
`
`with the same material as the —— as that used to make
`
`the first internal conductor lines.
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`It is not clear
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`how it is made.
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`The claim specifies that the common terminal,
`
`the layer which is made by the pixel electrode
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`material,
`
`is electrically connected to the first
`
`internal conducting lines.
`
`So someone skilled in the
`
`art could see that one way to do that is to have a
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`layer of the first internal conducting lines being
`
`connected —— electrically connected in the extractor
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`terminal region itself.
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`The specifications are not clear, and I believe
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`they're not providing a cross—section of the extractor
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`terminals itself. There is enough detail in the
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`cross—sections provided for the common contact
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`portions.
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`Another approach is to have the lower level --
`
`Q
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`Stop right there.
`
`Where in the specification is there a
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`disclosure that the common terminals are more than a
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`single layer of material?
`
`A
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`Q
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`In the specifications or in the claims?
`
`In ——
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`in the
`
`'lO2 Patent specification.
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
`
`847-406-3200
`
`
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`Page
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`23
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`A
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`For example,
`
`in Column 10, Line 15, it reads,
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`"Moreover,
`
`the contact holes for
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`connecting the internal conducting
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`lines 318," and in parentheses,
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`"207a
`
`and 207b," close parentheses, "with
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`the common terminals 205a and 205b at
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`the extractor terminals 205 were
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`formed."
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`So in this section here,
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`Column 10,
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`Line 15 to
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`18, it indicates that in the extractor terminal we
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`have the common terminals,
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`and there is a Contact hole
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`in the extractor terminal that connects with another
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`layer, and that layer could be the same layer as that
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`used to make the internal conducting lines 207a and
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`207b.
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`So someone skilled in the art would understand
`
`that you have the common terminal and there is a
`
`contact hole,
`
`there must be another layer below it,
`
`and hence it is disclosed is a multi—layer structure.
`
`Q
`
`But yet, you mean —— you think the common
`
`terminal is multi—layer or do you mean this whole
`
`composite of things in that sentence is multi—layer?
`
`A
`
`That the extractor terminal is a multi—layer
`
`structure. And one layer, which you have it in the
`
`files, a common terminal,
`
`is the Indium tin oxide.
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`312-442-9087
`
`Veritext Chicago Reporting Company
`800-248-3290
`
`847-406-3200
`
`
`
`There will be another layer, and the two will
`
`be connected.
`
`Q
`
`A
`
`They will be connecting in the Contact hole?
`
`There will be a contact hole.
`
`The —— the common terminal may be physically
`
`touching the other metal, and then there is -—
`
`Q
`
`"Other metal" meaning what?
`
`What other metal?
`
`A
`
`Like the metal that is making the 207a and
`
`207b, for example.
`
`Q
`
`Do you mean in the contact hole?
`
`A Well,
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`in general,
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`there are —— in making a
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`display,
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`there are multiple layers, multiple metal
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`10
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`Page 24
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`layers, and there are three such metal layers. There
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`is a metal layer used to make the gate lines or the
`
`gate electrodes,
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`the metal layer used to make the data
`
`lines and the source and drain electrodes, and there
`
`is the metal
`
`layer used to make the pixel electrodes.
`
`Two of those layers are used in the extractor
`
`terminals.
`
`Now,
`
`in addition to those layers,
`
`those
`
`conductive layers,
`
`there are two insulating layers.
`
`Q Where are the two layers —— where is it
`
`disclosed that the extractor terminals are two layers?
`
`Let me back up and withdraw that question.
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`Veritext Chicago Reporting Company
`800-248-3290
`
`847-406-3200
`
`
`
`Page 25
`
`A
`
`Because I can answer it,
`
`if you still want to
`
`place it.
`
`Q
`
`If you look at Column 10, Line 36, beginning at
`
`Line 36, it reads —— well,
`
`let me start at Line 31.
`
`"A thin metal film which would later
`
`be made into pixel electrodes 322 and
`
`the conducting pad 323 were formed to
`
`a thickness of 100 to 400 nanometers."
`
`Then there's —— that's a quote.
`
`Then
`
`there's another sentence which has to
`
`do with —— then there's another
`
`sentence after that that reads:
`
`"Then the thin metal film was
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`patterned to form the pixel electrodes
`
`322 and the connecting pad 323. This
`
`pad 323 measured 1.1 millimeters by
`
`1.1 millimeters was rectangular and
`
`covered the contact holes 321."
`
`Then the following sentence:
`
`"The extractor
`
`terminals 205 were also patterned."
`
`Do you understand that to mean that the
`
`extractor terminals were patterned from the same film
`
`as the pixel electrodes?
`
`A
`
`One layer of the extractor terminals was made
`
`and patterned at that time, and —— and that's the
`
`l5
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`Veritext Chicago Reporting Company
`800-248-3290
`
`847-406-3200
`
`
`
`Page 26
`
`claims refer to as the common terminal. That is -—
`
`that's the upper layer.
`
`The upper exposed metal
`
`layer.
`
`But the section I quoted ——
`
`Q Meaning Lines 15 through 18?
`
`A
`
`Right.
`
`It says that at the extractor terminals
`
`there are Contact holes, and that the internal
`
`conducting lines and the common terminals are
`
`connected in the extractor terminal regions.
`
`So there are multi—layer structures that are
`
`connected. Different layers are connected in the
`
`extractor terminals.
`
`Q What do you understand is meant
`
`in Lines 15 and
`
`16 by the phrase "contact holes for connecting the
`
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`internal conducting lines 318," paren,
`
`"207a and
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`207b," close paren, "with the common terminals 205a
`
`and 205b"?
`
`That's actually Lines 15 to 17.
`
`A
`
`As I stated earlier,
`
`there are three metal
`
`layers and there are also two insulating layers.
`
`The
`
`one insulating layer is the gate electric.
`
`Oh,
`
`actually,
`
`to be clear, it depends upon the device
`
`structure,
`
`there may be three insulating layers.
`
`For the -— the structure depicted in the —— in
`
`the prior art, which is a top gate TFT,
`
`the three
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
`
`847-406-3200
`
`
`
`Page 27
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`dielectric layers are the gate dielectric,
`
`the
`
`incremental dielectric between the scan line material,
`
`the gate dielectric metal, and the drain electrode
`
`metal. And then there is the passivation layer that's
`
`the third dielectric. All
`
`these are above the TFT
`
`structure.
`
`Q
`
`A
`
`Q
`
`Are you referring to a figure?
`
`Figure 13.
`
`The gate dielectric in Figure 13 is unlabeled,
`
`correct?
`
`There's not a number by it?
`
`No, it's not labeled.
`
`But it's the one that would override the gate
`
`A
`
`Q
`
`lines or the gate electrodes?
`
`1O
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`:0
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`A
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`It would be below the gate electrodes.
`
`It
`
`would be between the gate electrodes and the
`
`semiconductor that makes the thin—fi1m transistor.
`
`That's the gate electrode in these structures here.
`
`In amorphous silicon technology, which they
`
`have the bottom gate,
`
`in that technology the gate
`
`electrod
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