ROBERT SMITH-GILLESPIE, VOLJ
`
`08r’29r’2013
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Case Nos.:
`
`IPR2013-00029 & 00112
`
`) ) ) ) ) ) ) ) ) ) ) ) )
`
`XILINX,
`
`INC.
`
`Petitioner,
`
`INTELLECTUAL VENTURES I LLC,
`
`Patent Owner.
`
`
`
`VIDEOTAPED DEPOSITION OF
`
`ROBERT SMITH-GILLESPIE
`
`Volume I
`
`(Pages 1 through 165)
`
`
`
`Taken in behal" o" the Petitioner
`
`Thursday, August 29, 2013
`
`DOKICH COURT REPORTERS, INC.
`800-?20-96?9
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`XLNX-101 3
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`Page 1 of 165
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`
`
`08r’29r’2013
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Case Nos.:
`
`IPR2013-00029 & 00112
`
`) ) ) ) ) ) ) ) ) ) ) ) )
`
`XILINX,
`
`INC.
`
`Petitioner,
`
`INTELLECTUAL VENTURES I LLC,
`
`Patent Owner.
`
`
`
`VIDEOTAPED DEPOSITION OF
`
`ROBERT SMITH-GILLESPIE
`
`Volume I
`
`(Pages 1 through 165)
`
`
`
`Taken in behal" o" the Petitioner
`
`Thursday, August 29, 2013
`
`DOKICH COURT REPORTERS, INC.
`800-?20-96?9
`
`XLNX-101 3
`
`Page 1 of 165
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`
`
`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`PageZ
`
`BE IT REMEMBERED that the deposition of ROBERT
`
`SMITH-GILLESPIE, Volume I, was taken before Victoria A.
`
`Guerrero, Notary Public and CSR, RPR, CRR, on Thursday,
`
`August 29, 2013, commencing at the hour of 9:25 a.m.,
`
`in
`
`the conference room of the law firm of Schwabe
`
`Williamson & Wyatt, PC,
`
`in the City of Portland, County
`
`of Multnomah, State of Oregon.
`
`OOHJCSNU'IJb-UJNH
`
`APPEARANCES:
`
`For the Petitioner:
`
`HAYNES BOONE
`
`THOMAS KING
`
`1800 Von Karman, Suite 750
`
`Irvine, California
`
`92612-0169
`
`Phone 949.202.3059
`
`Fax 949.202.3159
`
`E-mail:
`
`Thomas.king@haynesboone.com
`
`For the Patent Owner:
`
`FOLEY & LARDNER LLP
`
`GEORGE E. QUILLIN
`
`CHRIS KALAFUT
`
`3000 K Street, NW, Suite 500
`
`Washington, DC
`
`20007-5143
`
`Phone 202.672.5413
`
`Fax 202.672.5399
`
`E-mail:
`
`unillin@foley.com
`E-mail:
`
`Ckalafut@foley.com
`
`DOKICH COURT REPORTERS, INC.
`800-?20—96?9
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`XLNX-1013
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`Page 2 of 165
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`ROBERT SMITH-GILLESPIE, VOLJ
`
`08:29:“2013
`
`APPEARANCES:(CODt'd)
`
`ALSO PRESENT:
`
`
`Walter Sanford, Videographer
`
`Don Coulman, Intellectual ventures IP Attorney
`
`DOKlCH COURT REPORTERS, INC.
`800-?20-967'9
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`XLNX-101 3
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`Page 3 of 165
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`ROBERT SMITH-GILLESPIE, VOLJ
`
`08r’29r’2013
`
`
`
`
`
`
` 4% "O *LXAM NA" ON
`
`
`
`
`
`
`
`
`' 4:85: Robert Smith-Gillespie
`
`
`
`MMMMMMmhbmeO
`
`
`:\K90'.)«JOWU'lIL“:(.0M|—‘0K90'.)«JOWU'lIL“:(.0M|—‘
`
`IIIIIIIl‘l‘l‘l‘l‘l‘l‘
`
`
`
`%
`
`
`
` 1% a.B
`
`
`
`
`
`
`
`
`:l
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`:\
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`DOKlCH COURT REPORTERS, INC.
`800-?20-96?9
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`XLNX-101 3
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`Page 4 of 165
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`INDEX TO EXHIBITS
`
`ROBERT SMITH-GILLESPIE
`
`Xilinx,
`
`Inc. v Intellectual Ventures 1 LLC
`
`Thursday, August 29, 2013
`
`Victoria A. Guerrero, CSR, RPR, CRR
`
`DESCRIPTION
`
`'545 patent; Exhibit No. 1001
`
`OOEJONU‘ILBLUMH
`
`
`
`
`
`(4 pages)
`
`'334 patent; Exhibit No. 1001
`
`(6 pages)
`Declaration of Robert
`
`Smith—Gillepsie in '334
`
`action; Exhibit No. 2008
`
`(33 pages)
`
`Takanashi reference, US Patent
`
`No. 5,264,951; Exhibit No.
`
`1003 (23 pages)
`
`Tannas reference, US Patent
`
`No.
`
`'334; Exhibit No. 2012
`
`(21 pages)
`
`Lee Patent, Exhibit 1004
`
`(8 pages)
`
`Declaration of Bruce Buckman,
`
`Ph.D.,
`
`in '334 action; Exhibit
`
`No. 1005 (57 pages)
`Board‘s Decision in the '334
`
`proceeding dated 6—17—13,
`
`Paper No. 14 (27 pages)
`Board‘s Decision in the '545
`
`proceeding dated 3—12—13,
`
`Paper No. 11 (29 pages)
`
`DOKICH COURT REPORTERS, INC.
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`Page 5 of 165
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`Xilinx,
`
`OOaJO‘XU'IJ—‘aLUMH
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`ROBERT SMITH-GILLESPIE, VOLJ
`
`08:29:“2013
`
`
`
`
`
`
`
`
` NDfiX ”
`% ”S (cont'd)
`'
`
`
`
`RO+LR'
`
`
`
`
`
`
`
`'H-G . NLSP *1
`'
`'
`
`
`
`
`
`Inc. v "
`'_ectual Ventures
`
`
`Thursday, August 29, 2013
`
`Victoria A. Guerrero, CSR, RPR, CRR
`
`
`
`
`
`
`
`DfiSCR P” ON
`
`
`
`
`
`
`
`
`Declaration of Robert
`
`
`
`
`Smith—Gi'iesp‘e in the '545
`
`
`matter; Qxhib‘t No. 2005
`
`(33 pages)
`
`
`Exhibit 11
`
`
`Lackner reference in '545
`
`matter, US Patent No.
`
`
`5,‘70,?71; ?xhibit 7011
`
`
`
`(13 pages)
`
`
`
`
`
`
`Declaration of Qruce Quckman
`
`
`in the '545 action; Exhibit
`
`No. 1006 (32 pages)
`
`DOKlCH COURT REPORTERS, INC.
`800-?20-96?9
`
`XLNX-1013
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`Page 6 of 165
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`Thursday, August 29, 2013,- 9:25 am.
`
`Portland, Oregon
`
`
`
`
`TFP. VTDFOGRAPFFTR: Good morning. My name is
`
`
`Walter Sanford,
`
`
`the videographer for I Witness Video
`
`
`
`Group of Irvine, California.
`
`
`
`This marks the beginning of Media No. l for the
`
`
`
`deposition of Robert Smith-Gillespie in the matter o:_
`
`Xilinx Incorporated, petitioner, versus Intellectual
`
`
`Ventures I, LIC, patent owner, pending before the Patent
`
`
`Trial and Appeal Board of the United States, Patent and
`
`
`
`
`Trademark 0""ice, Case No.
`
`IPR2013-00029, regarding
`
`
`Patent No. 5,632,545, under the title of Enhanced Video
`
`Projection System; and Xilinx Incorporated, petitioner,
`
`v Intellectual Ventures I, LLC, patent owner, pending
`
`IPR2013-0012 (sic), regarding Patent No. 5,779,334 under
`
`
`the title of Enhanced Video Projection system.
`
`o
`
`
`
`This deposition is being taken on beha1
`
`Xilinx Incorporated and is being held at the Pac West
`
`
`Center, Sm'te 1900, 1121 SW Fifth Avenue, Portland,
`
`Oregon 97204 on Thursday, August 29th, 2013.
`
`We are now going on the record.
`
`The time is
`
`
`
`DOKIC H COURT REPORTERS, INC.
`800-720-9679
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`XLNX-1 01 3
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`Page 7 of 165
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`approximately 9:25 Pacific Daylight Time. Counsel and
`
` before the Patent Trial and Appeal Board of the United
`
`
`
`
`States Patent and Trademark O
`ice, Case No .
`
`
`
`
`
`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`
`all others present will now identify themselves :
`
`
`
`record beginning with the deponent.
`
`
`TEE WITNESS: Oh, Robert Smith-GilleSpie.
`
`
`
`MR. QUTTJTN:
`"m George Quillin on behal
`
`o
`
`
`
`
`
`Home address?
`
`the patent owner, Intel 'ectual Ventures. With Ire is my
`
`
`
`
`
`colleague, Chris Kala-Sut. Roth o: us are from the law
`
`
`
`
`"irm o" Foley & Tardner LIP. And also with us is a
`
`
`representative from patent owner, Mr. Don Coulman.
`
`MR. KING:
`
`
`
` o" Xilinx.
`
`
`Iom King from Haynes & Boone here on
`
`
`
`
`IFP. VTDROGRAPFFR:
`
`The court reporter will now
`
`administer the oath.
`
`ooOoo
`
`ROBERT SMI TH-GILLESPIE ,
`
`
`having first been sworn by the Notary Public,
`
`
`
`
`fied under oath as follows:
`
`
`
`EXAMINAT ION
`
`BY MR. KING:
`
`Q
`
`Good morning.
`
`A
`
`Q
`
`Morning .
`
`Would you please state your name and address,
`
`
`or your address for the record?
`
`A
`
`DOKIC H COURT REPORTERS, INC.
`80(J-7’20-96'f9l
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`XLNX-1 01 3
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`Page a of 165
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`Yes.
`
`
`
`2790 Iimberline Drive, Eugene, Oregon.
`
`
`
`I understand you‘ve been deposed be:
`
`Now,
`
`DerDfitODfirODfirO
`
`Q
`
`Idc.
`
`I have.
`
`Approximately how many times?
`
`Probably around ten times.
`
`Always in patent matters?
`
`Yes.
`
`Now,
`
`I understand that since you‘ve been
`
`
`
`
`
`deposed before you‘re probably familiar with the ground
`
`
`rules for depositions?
`
`A
`
`Q
`
`Yes,
`
`I am.
`
`
`And so I don‘t want to Spend a lot of time on
`
`this, but you understand that we‘re here to have a
`
`conversation about the opinions that you‘ve expressed on
`
`
`
`two di
`"erent patents , right?
`
`A
`
`Q
`
`That's my understanding, yes.
`
`Okay. And you understand that Mr. Quillin here
`
`
`is here to mpresent interests of his client,
`
`Intellectual Ventures, right?
`
`A
`
`Q
`
`Yes.
`
`
`And from time to time he‘ll make objections;
`
`but notwithstanding his objections, you understand that
`
`you need to reSpond to my questions, right?
`
`A
`
`DOKICH COURT REPORTERS, INC.
`800-?20-96?9
`
`XLNX-101 3
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`Page 9 of 165
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`Q
`
`I'm going to hand you two exhibits.
`
`
`(Exhibit 1, Exhibit No. 1001 from ‘545 IPR, was
`
`marked . )
`
`
`(Exhibit 2, Exhibit No. 1001 from ‘334 IPR;
`
`Exhibit No. 1001, was marked.)
`
`BY MR. KING:
`
`Q
`
`
`The first I'm going to mark as Exhibit I. This
`
`
`is Exhibit 1001 from the ‘545 IPR.
`
`Have you seen this document be:
`
`
`
`Yes,
`
`I have.
`
`And you understand that this is the patent at
`
`A
`
`Q
`
`
`
`issue in the ‘545 IPR?
`
`A
`
`Q
`
`Yes,
`
`I do.
`
`Okay.
`
`I‘m also going to hand you what I've
`
`marked as Exhibit 2. And this is Exhibit 1001 in the
`
`‘334 matter. And it‘s the ‘334 patent, correct?
`
`A
`
`Q
`
`That‘s correct.
`
`Now,
`
`I understand that you have some experience
`
`with liquid crystal displays, right?
`
`A
`
`Q
`
`Idc.
`
`Can you describe your experience with ICDs :
`
`
`
`A
`
`Sure.
`
`I worked beginning in around 1989 doing
`
`
`
`_ and user interface diSplays on comercial aircraft
`
`
`
`_ay design and research and development for control
`
`
`
`DOKICH COURT REPORTERS, INC.
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`while I was at Honeywell.
`
`
`worked really will LCD manufacturers in the US
`
`to develop some control panel LCDs.
`
`The lighting
`
`associated with those LCDs as well.
`
`Then moved on to
`
`
`larger diSplays for instruments such as what's called an
`
`attitude position indicators, TCOS. They‘re rotpflr
`
`
`
`LCD performance, designing backlight systems, ancillary
`
`3 1/2 inch square displays.
`
`
`
`
`Then was involved in the developnent o:
`
`
`triple seven large format LCDs, active matrix,
`
`eight-inch displays. For that program I was reSponsible
`
`
`primarily for the backlight in the beginning and then
`
`
`LCD supplier optimization for the actual TFC cell.
`
` After my work in Honeywell I moved on to
`
`Throo-Fivo Systcms whoro Three-Five Systems was a
`
`
`
`
`manufacturer of liquid crystal diSplays for cell phone,
`
`
`
`
`
`medical devices, o""ice instrumentation; that sort of
`
`thing .
`
`They had an automated processing line in
`
`Arizona.
`
`So we not only designed and -- designed the
`
`
`
`
`displays, we built the LCDs as well. Though, for
`
`back-end processes we sent those elsewhere.
`
`
`
`
`So I was involved in, most of the tine,
`
`optimizing the display assembly, not doing the LCD --
`
`
`the LCD design itse f, but basically characterizing the
`
`
`
`
`
`DOKKHiCOLRJ‘REPORTERS,DKI
`8(J(]-7"2(]-967"9l
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`XLNX4013
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`P89811 0f165
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`
`requirements for it.
`
`Then beyond that,
`
`I just stayed involved doing
`
`
`product design, recordization for liquid crystal panels.
`
`
`
`Because after -- after those diSplays, pmetty much
`
`everything is built in Asia and now purchased as what we
`
`
`call commercial o
`
` "-the-shelf and then_medified as
`
`
`
`ambient environment.
`
`
`
`neces sary .
`
`But I‘ve been basically working in the LCD
`
`
`
`
`
`"or over 25 years.
`
`Q
`
`Okay.
`
`I noticed that you mentioned lighting
`
`and backlighting a couple times in your response.
`
`Can you explain to me what that means?
`
`A
`
`Pbst LCDs, not all, but most are passive
`
`
`devices that require some sort of illumination. well,
`
`a" TCDs are passive devices.
`
`i
`'umination,
`
`Some require rear
`
`
`some utilize :ront illumination, such as,
`
`
`
`
`
`
`
`say, a calculator or watch diSplay.
`
`
`So most of the product I've been involved with
`
`have either been transmissivity requiring backlighting
`
`
`
`
`or transflective requiring backlighting and optmmization
`
`
`
`
`
`"ront surface properties as well.
`
`o
`
`Q
`
`A
`
`
`Transflective; what does that mean?
`
`PEans that the display acts in both
`
`
`transmissivity and reflective modes depending upon the
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`Q
`
`Can you explain that in lay terms?
`
`A
`
`Okay.
`
`So on your watch you have a little back
`
`light. And when it gets dark you press the button, at
`
` least I do, and the little Indiglo thing comes on and I
`
`
`
`see the characters illuminated from behind.
`
`
`But in daylight mode it operates in reflective.
`
`You have dark characters on kind of a silver background
`
`and we‘re just using the ambient illumination.
`
`Q
`
`I thought I heard you say that you, at least
`
`
`
`provide -- figure out how to provide the best
`
`
`
`right now, you don‘t build ICD panels; is that right?
`
`A
`
`
`One of the companies that I'm involved with,
`
`I
`
`
`
`
`guess -- let me clarify what I did say.
`
`I said
`
`primarily LCD panels nowadays are built in Asia. And --
`
`
`for active matrix cells, at least. And they‘re brought
`
`the involvement now is
`in as modules. And typically,
`
`
`
`
`more around using ccmmercia' o""-the-shelf product and
`
`
`
`
`modifying it.
`
`So disassembling the product and enhancing it
`
`
`in various ways through a lot of what I've done is
`
`
`backlight design for conversion to very high bright
`
`
`back ights for outdoor applications.
`
`
`
`
`Night vision, filtering, and then also
`
`installing heaters to extend operating temperature
`
`range, you know, characterizing the displays to
`
`
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`
`performance and meet customers' needs in rugged -- in a
`
`rugged environment.
`
`Q
`
`Okay.
`
`
`I want to get a sense for where in the
`
`LCD Space you have expertise.
`
`So why don‘t I ask it
`
`this way: Can you, at a high level, just describe the
`
`
`key components of a typical LCD panel in, say, 1993?
`
`A
`
`Okay. Starting with the liquid crystal cell,
`
`
`
`
`
`you essentially have two glass plates separated by some
`
`small Space, roughly three -- well,
`
`in 1993 it would be
`
`
`The cell is sealed with
`probably around five microns.
`
`
`an epoxy pcrinctcr seal between the two pieces of glass.
`
`
`well, really on the inside if you‘re drawing. And then
`
`
`
`it's filled with fluid.
`
`
`
`would it help to draw a picture?
`
`A
`
`I‘ll explain it.
`
`
`The cell is filled with a
`
`
`liquid crystal fluid and then a little plug seal is
`
`administered. And inside the liquid crystal diSplay
`
`
`
`
`would be, for the type of diSp ays that I've worked on,
`
` would be the, basically,
`
`
`
`
`
`photolithOgraphic process.
`
`
`
`the electrodes for the pixels,
`
`
`or if you want to look at character diSplays also,
`
`charactcrs thcmsclvcs, scgmcnt clcctrodcs,
`
`the
`
`those are
`
`
`usually forned.on the glass as a tranSparent metal oxide
`
`called Indium tin oxide, which is installed via
`
`photolithOgraphic process or a pattern via
`
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`In active matrix displays there‘s additionally
`
`
`
`thin fihn transistors that are formed on one glass that
`
`
`connect to each of the pixels in the cell. And then
`
`
`also to row and column drivers. And further on the
`
`other glass that does not have the active matrix array
`
`
`
`
` form on it, there would be color Silters :ormed.
`
`
`Typically stripes o: red, green, and blue, one
`
`
`
`thin "1 m
`
`per pixel, corresponding each to a IFI,
`
`
`
`
`
`transistor on the opposite plate.
`
`So that‘s the cell.
`
`Attached to the cell are electronic components --
`
`Q
`
`A
`
`Q
`
`Can we stop with the cell?
`
`Okay.
`
`I‘ll come back to this, but I just have a
`
`couple questions about the cell.
`
`A
`
`Q
`
`Okay.
`
`So I just want to make sure I have this
`
`straight.
`
`In an ICU cell there are two glass plates
`
`that are separated by a very small distance, right?
`
`A
`
`Q
`
`Yes.
`
`And in between those plates there is -- there
`
`are liquid crystal molecules that are trapped between
`
`those plates, right?
`
`A
`
`Q
`
`Yeah. Fluid contained between, yeah. Okay.
`
`
`And then one of the plates has an electrode on
`
`it made out of Indium tin oxide? Or is that on both o:
`
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`the plates?
`
`
`That would be on both o:
`5 the plates.
`
`
`Is that on the side o:
`f the glass plate that is
`
`A Q
`
`
`f the glass
`touching the liquid crystal or on the side o:
`
`plate that‘s not touching the liquid crystal?
`
`A
`
`
`It‘s on the side o:
`f the glass plate that‘s
`
`touching the liquid crystal.
`
`Q
`
`
`And then you mentioned some thin film
`
`transistors that make up a pixel, right?
`
`Or that make
`
`up the pixels?
`
`A
`
`
`
`"Werent
`In a particular -- so there are di
`
`
`matrix diSplays just simply have rows and columns o:
`
`ITO.
`
`That‘s the Indium tin oxide. And the active
`
`matrix diSplays have thin
`
`
`film transistors
`
`
`formed on one
`
`
`
`
`= ITO
`5 glass and the other has an array o:
`of the pieces o:
`
`only.
`
`Q
`
`So let‘s talk about the active -- let‘s just
`
`talk about the active matrix 1CD type.
`
`A
`
`Q
`
`Okay.
`
`So in the active matrix 1CD type, are the thin
`
`
`
`
`
`film transistors formed on the side of -- they‘re forned
`
`
`on one side of the glass, right?
`
`A
`
`Q
`
`That‘s correct.
`
`
`And is it the side of the glass that‘s touching
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`
`
`varieties, flavors o:
`5 liquid crystal diSplay.
`
`Passive
`
`
`
`
`
`
`
`ROBERT SMITH-GILLESPIE, VOL.I 08f29f2013
`
`
`the liquid crystal? Or is it the side of the glass
`
`that‘s not touching the liquid crystal?
`
`A
`
`
`It‘s on the side of the glass that's touching
`
`the liquid crystal.
`
`So basically,
`
`internal to the cell.
`
`Q
`
`Those transistors don‘t stretch so that they
`
`cover -- so that they touch the other electrode, right?
`
`
`
`
`let me ask a di
`
`erent way.
`
`
`Those -- those thin fihn transistors that are
`
`touching the liquid crystal, do they also touch the
`
`other plate of glass?
`
`
`
`A
`
`No. There has to be liquid crystal between the
`
`
`thin fihn transistors and the other plate.
`
`So they‘re
`
`
`
`on top of that you would have transistors, right?
`
`
`
`very small in height.
`
`about.
`
`
`
`I mean, probably microns. And
`
`then_there‘s usually a layer that I didn't tell you
`
`What they wou'd call a planarization layer.
`
`
`And then a layer, an alignment layer made out o;
`
`
`
`
`polyimide that‘s spin cast onto the plates after the DFT
`
`structure‘s gone down. And that acts as -- that‘s
`
`mechanically or optically adfiusted to provide alignnent
`
`
`
`to the liquid crystal at the inter"ace o" the plate.
`
`
`
`Q
`
`Okay.
`
`
`So looking at the plate of glass that
`
`
`has the transistors on it, so if you were just looking
`
`at that glass plate, you‘d have a glass plate and then
`
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`A
`
`In a very simplistic model, yes.
`
`Q
`
`
`And then on tOp of the transistors, what would
`
`you have?
`
`A
`
`well,
`
`the transistors connect to transparent
`
`conductor material,
`
`the ITO.
`
`So they basically are
`
`electrically attached to ITO.
`
`
`Then over tOp of
`
`transistors is probably a black mask to prevent
`
`
`activation of the transistors.
`
`Black mask is,
`
`
`in this period 0: time,
`
`
`say 199- -- 1996 tine frame, it would have been
`
`chromium oxide.
`
`Q
`
`The glass,
`
`then above the glass the
`
`transistors?
`
`Yes.
`
`Then above the transistors an ITO layer?
`
`Adjacent to the transistors.
`
`I'm sorry. Adjacent to the transistors.
`
`MADAM COURT REPORTER: Can you repeat that
`
`A
`
`Q A
`
`Q
`
`A
`
`part :
`
`Q
`
`Ard then actacent to those transistors on the
`
`
`
`glass is ar ITO layer, right?
`
`Tr en going up a layer?
`
`
`
`That‘s correct.
`
`At“
`
`d then --
`
`Ard then there‘s --
`
`A
`
`Q
`
`A
`
`Q
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`Eolyner layer above that.
`
`Okay.
`
`TmagfwfirlmerispdyHMda mthanZ. HE
`
`
`
`
`
`Q
`
`A
`
`key is to make that as small as possible relative to the
`
`polyimide itself is, at this tine, was mechanically
`
`rubbed, 1996,
`
`
`
`to provide surface alignment of the liquid
`
`
`crystal material on the cell surface,
`
`inner cell
`
`
`surface.
`
`Q
`
`Okay. And then what‘s above -- what‘s the next
`
`layer up from the polymer layer?
`
`
`
`Liquid crystal.
`
`A
`
`Q
`
`So the liquid crystal doesn't actually touch
`
`
`
`the transistors physically, right?
`
`A
`
`No. There‘s a separation layer to protect
`
`them, obviously. That‘s the polyimide.
`
`Q
`
`And that's because liquid crystal is a
`
`sensitive material and transistors are sensitive and you
`
`don‘t want them touching each other because they might
`
`chemically react?
`
`A
`
`I think they‘re pmetty much protected by the
`
`chromiwn layer, chromium chromium oxide black layer; but
`
`
`
`there‘s no reason to not just pattern the polyimide over
`
`the whole glass substrate.
`
`The pixel area where the TET is located is not
`
`a light emitting area.
`
`It's usually kept dark.
`
`So the
`
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`
`
`" the pixel .
`
`Q
`
`Okay. And then the liquid crystal layer itsel:
`
`
`
`is just a continuous layer across the entire diSplay,
`
`right?
`
`A
`
`Q
`
`That‘s correct.
`
`All right.
`
`So above the liquid crystal layer
`
`
`there‘s going to be another plate of glass, right?
`
`A
`
`Q
`
`Yes.
`
`
`
`
`Starting from the part of that plate of glass
`
`that touches the liquid crystal, can we keep on going up
`
`
`the stack and can you describe that for me, please?
`
`Sure. There would be a polyimide layer, a
`A
`
`
`co' or filter layer that would be basically three
`
`
`
`di ""erent colors apply down, you know,
`
`three per pixel,
`
`
`
`basically,
`
`
`forming red, green, and blue sub pixels.
`
`And then there may be some black mask between
`
`the outside --
`
`Q
`
`Sorry. Above the planer TTO is the glass,
`
`Yes.
`
`Sorry. You were saying on the outsides?
`
`Would be polarizers placed on each glass.
`
`
`
`
`
`right?
`
`A
`
`Q A
`
`Q
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`Would that be physically connected to the glass
`
`
`
`them.
`
`I'm not certain at the time of this patent. Then
`
`above that would be the TTO, planer ITO layer. Then on
`
`
`
`
`
`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`or would that be a separate element?
`
`A
`
`Q
`
`laminated,
`
`too.
`
`
`So the polarizer would be fabricated as a
`
`
`separate element from the glass and then it would be
`
`connected by a process?
`
`
`
`
`It‘s a sheet o
`11m.
`
`Yes.
`
`A
`
`Q
`
`A
`
`Q
`
`And there‘s a polarizer on each side?
`
`I'm sorry.
`
`I didn‘t hear you.
`
`
`There‘s a polarizer outside of each plate o:
`
`
`
`
`
`glass, right?
`
`That‘s correct.
`
`Are there any other elements that make up an
`
`A
`
`Q
`
`LCD cell?
`
`
`
`A
`
`well,
`
`there‘s the porinotcr seal which is
`
`
`usually an epoxy layer that's forned.-- if you have a
`
`rectangular display, an epoxy layer is screen printed
`
`
`
`preformed.
`
`
`
`down with leaving a little Opening at the end. And
`
`there‘s also typically spacers inside the cell which I
`
`
` That's how you keep the glass apart. They‘re
`
`didn't tell you about either.
`
`micro beads that set the cell gap. And the micro beads
`
`
`are present also in the perimeter seal. And before the
`
`liquid crystal is inserted,
`
`
`the planes of glass are
`
`
`
`brought together and, on the seal, that's, you know,
`
`
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`released, and then the little port that the liquid
`
`
`
`
`
`"inally with a Uvecured
`crystal entered in is sealed o
`
`epoxy. That‘s your whole cell.
`
`Q
`
`Okay. And what you just described was an
`
`active matrix LCD cell, right?
`
`A
`
`Q
`
`That‘s correct.
`
`
`Okay. And if we just look at Exhibit 1, which
`
`is the ‘545 patent.
`
`A
`
`Q
`
`Okay.
`
`
`would the system of the ‘545 patent use the
`
`active matrix LCD cell that you just described?
`
`A
`
`No, it would not use the active matrix that I
`
`described.
`
`Q
`
`How would the -- how would the LCD cell o:
`
`
`
`
`‘545 system di
`er "rom what you just described?
`
`A
`
`
`
`
`It would not have the color :ilters :ormed
`
`
`
`
`
`That‘s the ‘334 patent.
`
`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`And then that assembly is secured,
`
`then it‘s
`
`evacuated in a vacuum chamber. And then liquid crystal
`
`is allowed to basically move by capillary action into
`
`
`
`to :ill the 'iquid crystal cell,
`the cell
`
`the vacuwn‘s
`
`
`
`inside the cell.
`
`
`
`
`Okay. Any other di
`
`No.
`
`All right. Now, let's look at Exhibit 2.
`
`Q
`
`A
`
`Q
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`A
`
`Q
`
`Okay .
`
`
`
`
`
`Are there any di
`
`erences between the ICD cell
`
`that you just described and the LCD cell that would be
`
`used with the system of the ‘334 patent?
`
`
`
`the co' or filters would not be formed
`
`A
`
`Again,
`
`
`
`inside the cell.
`
`
`So the ICDs of this patent and the
`
`previous one are what are called n‘onochrome LCDs. Oh,
`
`
`and I need to amend my previous answer, if you don‘t
`
`mind.
`
`The pixel structure would not be a three-pixel
`
`
`
`structure. Because if you remove the color filters,
`
`then you don‘t need to have a red, green, and blue thin
`
`
`
`film transistor, one each for those sub pixels.
`
`
`So you reduce the number of -- I didn't say
`
`
`what the number of transistors were, but just to
`
`
`clarify,
`
`
`in a monochrome ICD you would have fewer thin
`
`
`film transistors.
`
`In a monochrome active matrix ICD.
`
`Q
`
`But those transistors would still be located in
`
`the same place, right?
`
`
`
`All right.
`
`Yes.
`
`A
`
`Q
`
`
`
`
`Any other di ""erences between the ICD cell that
`
`you described and the LCD cell that's described in
`
`
`
`either the '334 or the ‘545 patents?
`
`I don‘t believe so.
`
`A
`
`Q
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`A
`
`I did happen to say that there‘s a black mask
`
`in both the patents. They say an aluminum process can
`
`
`be used for the mask.
`
`Q
`
`A
`
`Okay .
`
`
`
`
`
`So that could be a minor di ""erence. But I did
`
`say that it could have been something other than
`
`chromium chromium oxide. Go ahead.
`
`Q
`
`
`So looking at the plate of glass that has the
`
`
`transistors, where does the black mask fit on the stack
`
`
`
`of that g'ass p'ate?
`
`A
`
`
`
`
`
`’t wou'd be over top of, that‘s towards the
`
`
`
`liquid crystal-facing sur "ace o " the active matrix, o:
`
`
`the thin film transistor. And typica"y,
`
`the address
`
`So can you --
`
`
`
`
`
`
`
`
`
`
`lines. Because they would be very re- 'ective a' so.
`
`Q
`
`Okay. Would that be underneath the polymer
`
`A
`
`Yes.
`
`Q
`
`A
`
`Q
`
`Would it be underneath the IIO layer?
`
`
`IIO is probably -- hIrm. Can‘t say for certain.
`
`Whatever it is, it doesn‘t touch the liquid
`
`
`crystal itsel::, right?
`
`A
`
`Q
`
`
`
`
`
`
`
`
`
`Black layer does not touch the liquid crystal.
`
`
`
`
`A" right. We started this conversation on ICD
`
`
`I asked you what were the major components o:
`
`
`
`
`
`_ diSplay and I cut you o
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`A
`
`Actually,
`
`
`I believe you asked of a liquid
`
`crystal display.
`
`Q
`
`
`Of a liquid crystal diSplay. All right.
`
`
`
`Thanks for that clarification.
`
`So I want to -- can you
`
` a
`keep on running through the other major elements o;
`
`liquid crystal display?
`
`
`
`
`
`
`the III pixels is connected through column and row
`
`A
`
`Can you te" me which type of liquid crystal --
`
`give me an example of a liquid crystal display that you
`
`
`
`would like me to describe.
`
`Q
`
`Okay.
`
`So I think you‘re asking, am I asking
`
`
`about projection or I‘m asking about flat panels?
`
`A
`
`Q
`
`I want to be sure.
`
`
`Okay. we will ultimately get to both of them.
`
`So let‘s start with -- but I want to start with where
`
`your experience is.
`
`I understand your experience is
`
`
`more with flat panels than with projectors, right?
`
`A
`
`Q
`
`That‘s correct.
`
`
`Iet‘s start with the flat panel side.
`
`Can you tell me the major -- at a very high
`
`
`level, can you tell me the major components of a --
`
`A
`
`Okay.
`
`
`So we‘ll try and sift through this.
`
`So
`
`you have to drive the pixels. That means basically
`
`
`apply a voltage field across the cell.
`
`To do that you
`
`have to connect to the outside world. Okay?
`
`
`So each o:
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
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`address lines which go to ledges on the outside o:
`
`cell.
`
`And those ledges, so the glass is -- the two
`
`
`pieces of glass are not the same size.
`
`I guess I should
`
`point that out to you. The, what we call the bottom
`
`
`
`Those, at the tine of these inventions, were
`
`glass,
`
`that would be the TFT glass, has a ledge on, you
`
`know, at least one edge, on which electronic
`
`interconnect circuitry is attached.
`
`Those circuits,
`
`
`typically called flexes or
`
`tabs, contain driver chips on them that set up the
`
`
`voltage signal for each pixel. Okay.
`
`Then behind the -- so just moving to the
`
`outside now, behind the liquid crystal display there
`
`needs to be a light source, whether it‘s projection or
`
`notebook computer or TV.
`
`So the light source is
`
`
`
`
`typical y :orned.either as an array of lamps, behind
`
`
`some di
`"users, such as in a TV, you know, flat panel
`
`
`
`
`TV, LCD TV.
`
`
`
`Or it can be lit through a -- what‘s called a
`
`light guide assembly, which would be a transparent
`
`
`acrylic plate that has illumination from the edge. And
`
`
`basically it illuminates a structure that unifiorm'y
`
`
`
`
`distributes the light on the rear suriace o" the 'iquid
`
`
`
`crystal panel.
`
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`
`typically fluorescent lamps in an edge lit. Actually,
`
`
`fluorescent lamps in a direct view as well.
`
`I actually did some designs even earlier where
`
`we were using incandescent lamps that were heavily
`
`
`
`filtered for backlighting LCDs. Nowadays, it‘s moving
`
`towards LEDs.
`
`Q
`
`Okay. Are there any other major components
`
`
`that would go into a flat panel display?
`
`
`
`A
`Structures. Optical films to help boost
`
`
`
`
`
`
`
`
`e "iciency, reflector films to drive the 'ight forward,
`
`
`
`illumination of the display, yes.
`
`
`
`housing that would support the entire structure. And
`
`then_there‘s a controller board that would attach to the
`
`TET chips.
`
`Q
`
`Okay. Tell me about that controller board.
`
`Can you describe it in_more detail?
`
`A
`
`Typically, it sets up the timings and signal
`
`levels in response to some incoming signal and sends it
`
`
`
`
`out to -- it has a bunch o" shi"t registers on it, you
`
`know, basic -- the main blocks are timing controller,
`
`
`shift registers, and D to_A and A to D converters.
`
`Q
`
`All right. Now,
`
`
`from reading your CV, it looks
`
`
`like you have a lot of experience with the backlight
`
`component; is that right?
`
`A
`
`lighting in general, but relative to LCDs,
`
`
`
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`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`Q
`
`
`Okay. What about the 1CD cell itsel .
`
`have experience making or designing LCD cells?
`
`A
`
`Q
`
`Yes,
`
`I do.
`
`
`Can you describe that for me?
`
`A
`
`
`Probably the first experience was having to
`
`
`redesign an aircraft display that's used in a control
`
`panel on the 737.
`
`
`From a sort of a low performing
`
`
`
`
`
`
`
`design that used a technology ca led dichroic 'ignid
`
`crystal, which_neans that there are dye mo ecu es
`
`attached to a highly wound up cholesteric liquid
`
`crystal, very slow responding, especially at cold
`
`
`temperatures, poor viewing angle perfornence.
`
`So I worked very closely with a US display
`
`supplier to develop -- to develop -- to ccnnercialize an
`
`older technology that really hadn‘t been -- hadn't been
`
`I was really sort of the optics and
`
`
`
`ccnnercialized for that application.
`
`
`
`Actually ran experiments with them at their
`
`
`The type of ce'l
`
`that we developed was called
`
`
`facility.
`
`a Heilneier liquid crystal cell and it‘s known to have
`
`much faster response tines, bottcr viewing angle
`
`
`
`
`performance. There‘s a published paper that is in my CV
`
`around that.
`
`
`
`
`
`And then at Three-Five Systems I was heavily
`
`involved in basically tweaking designs of super twisted
`
`nematic displays.
`
`
`
`
`
`DOKKHiCOLRJ‘REPORTERS,DKI
`8(J(]-7"2(]-967"9l
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`
`
`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`lighting guy .
`
`You know,
`
`
`to achieve certain performance
`
`targets we'd make minor changes to rub directions, cell
`
`gap;
`
`things like that.
`
`So even though I'm not the guy
`
`down there, you know,
`
`turning the dials on the machine,
`
`
`I was part of the team.
`
`Q
`
`And would you say that designing LCD cells was
`
`
`
`
`
`one o" the "ocuses of your career or was your career
`
`
`really more focused on backlighting?
`
`A
`
`Not designing ICD cells, no. That's a very,
`
`
`you know, specialized field. People -- people earn
`
`Ph.D.s at places like Kent State to do ICD cell design
`
`
`and opthnization. Mine is more productization o;
`
`products that utilize liquid crystal.
`
`Q
`
`Okay.
`
`So were you -- were you helping people
`
`
`to tweak the designs of their TCD cells? ’s that what
`
`
`
`you were describing earlier?
`
`A
`
`That's what I did, yes. And then, like, on
`
`the -- the Boeing 777 program,
`
`I was given
`
`
`
`responsibility after the cell was designed, of course,
`
`by a Japanese company, working very closely with them on
`
`control parameters to optimize and stabilize variation
`
`
`
`I was not the guy
`
`in the cell.
`
`So, you know,
`
`
`aspects of the design. But, again,
`
`I was integra ly involved in many
`
`
`
`DOKKHiCOLRJ‘REPORTERS,DKI
`8(J(]-7"2(]-967"9l
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`XLNX4013
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`Page 29 Of '165
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`
`
`And all of those components existed in 1996
`
`ROBERT SMITH-GILLESPIE, VOLI 08f29f2013
`
`doing the -- running the analysis program.
`
`Q
`
`Okay. Now, what about the controller board
`
`
`component? was that a focus o: your career, working on
`
`
`the controller aspects of the 'iqnid crystal display?
`
`
`
`A
`
`Q
`
`NO.
`
`Okay. And then so we‘ve been talking about
`
`
`
`flat panels so far. Can you tell me what the Hefior
`
`
`components of a projection system or liquid crystal
`
`projection system are?
`
`A
`
`Q
`
`A
`
`Which type would you like me to talk about?
`
`well, what types are there?
`
`Place to start. There are transmissive and
`
`Additionally,
`
`there could be things like
`
`
`
`pdflfimgmmsgfimm,wmmmfflmmfw
`
`extracting col
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