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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WINTEK CORPORATION,
` Petitioner,
` Case IPR2013-00567
` vs. IPR2013-00568
`TPK SOLUTIONS INC.,
` Patent Owner.
`----------------------------------
`
` DEPOSITION OF DR. VIVEK SUBRAMANIAN
` Palo Alto, California
` Wednesday, June 11, 2014
`
`REPORTED BY:
`CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
`JOB NO. 80920
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`TSG Reporting - Worldwide 877-702-9580
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`TPK 2009
`Wintek v. TPK Touch Solutions
`IPR2013-00567
`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WINTEK CORPORATION,
` Petitioner,
` Case IPR2013-00567
` vs. IPR2013-00568
`TPK SOLUTIONS INC.,
` Patent Owner.
`----------------------------------
`
` DEPOSITION OF DR. VIVEK SUBRAMANIAN
` Palo Alto, California
` Wednesday, June 11, 2014
`
`REPORTED BY:
`CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
`JOB NO. 80920
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`TPK 2009
`Wintek v. TPK Touch Solutions
`IPR2013-00567
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`Page 2
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` June 11, 2014
` 9:00 a.m.
`
`Deposition of DR. VIVEK SUBRAMANIAN, held at
`Finnegan Henderson Farabow Garrett &
`Dunner, 3300 Hillview Avenue, Palo Alto,
`California, before Cynthia Manning, Certified
`Shorthand Reporter No. 7645, Certified LiveNote
`Reporter, California Certified Realtime Reporter.
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`APPEARANCES:
`
`FOR PETITIONER:
` QUINN EMANUEL URQUHART & SULLIVAN
` BY: DAVID BILSKER, ESQ.
` 50 California Street
` San Francisco, CA 94111
`
`FOR PATENT HOLDER:
` FINNEGAN HENDERSON FARABOW GARRETT &
` DUNNER
` BY: JOSEPH PALYS, ESQ.
` ABHAY WATWE, ESQ., Ph.D.
` Two Freedom Square
` 11955 Freedom Drive
` Reston, VA 20190
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`APPEARANCES:
`
`Also present:
` Gokalp Bayramoglu, AWQ Consulting Inc.
` Nihat Deniz Bayramoglu, TPK Solutions Inc.
` Huanyi Linm TPK Solutions Inc.
` Alan Diaz, Videographer
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` PALO ALTO, CALIFORNIA;
` WEDNESDAY, JUNE 11, 2014; 9:00 A.M.
`
`Page 5
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` THE VIDEOGRAPHER: Good morning.
` My name is Alan Dias from TSG Reporting.
`This is a matter pending before the United States
`Patent and Trademark Office, before the Patent Trial
`and Appeal Board. Case number IPR2013-568,
`IPR2013-567.
` We are located today at 3300 Hillview
`Avenue, in the City of Palo Alto, California. Today
`is June 11, 2014. The time is 9:00 a.m.
` Here with me is Cynthia Manning, also from
`TSG Reporting.
` Counsel, will you please identify yourself
`for the record?
` MR. BILSKER: This is David Bilsker, from
`Quinn Emanuel, representing the Patent Owner, TPK.
` And with me is Alp Bayramoglu and Nihat
`Bayramoglu from TPK. And that's
`B-A-Y-R-A-M-O-G-L-U.
` MR. PALYS: Joseph Palys, with Finnegan,
`representing Petitioner Wintek Corporation. And
`with me is Abhay Watwe, also from Finnegan.
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` THE VIDEOGRAPHER: Will the court reporter
`please swear in the witness.
`
` VIVEK SUBRAMANIAN,
` having first been duly sworn, testified as
` follows:
`
` THE VIDEOGRAPHER: You may proceed.
` MR. PALYS: David, before you begin, I want
`to put something on the record.
` MR. BILSKER: Sure.
` MR. PALYS: I just want to put on the
`record that in addition to IPR2013-567 and
`IPR2013-568, that this deposition is also relating
`to IPR2014-00541.
` MR. BILSKER: Yeah. And I agree with you
`that it's 567 and 568. I think it may be a little
`bit up in the air as to whether it's for 541 as well
`since no IPR has actually been declared on 541 yet.
` So I think that's a little bit ambiguous as
`to whether it's actually taking place with respect
`to that IPR as well.
`//
`//
`//
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` EXAMINATION
`
`Page 7
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`BY MR. BILSKER:
` Q. Good morning, Dr. Subramanian.
` A. Good morning.
` Q. I might not have got a correct
`pronunciation that time.
` You have submitted declarations in three
`IPRs against TPK's United States Patent, the '902
`patent; correct?
` A. That's correct.
` Q. And you consider yourself to be an expert
`in touchscreen technology?
` A. Yes.
` Q. Let me pass you a copy of your CV, which
`was marked as Exhibit Number 1013 in the 547 IPR.
` A. I have it in front of me.
` Q. Do you recognize that document?
` A. Yes. This is my curriculum vitae, along
`with a list of patents, publications, and
`representations.
` Q. And there is a rather large list of patents
`and publications here, aren't there?
` A. Yes.
` Q. And you prepared this list?
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` A. Correct.
` Q. Now, in this long list of patents and
`publications, none of them deal with touchscreen --
`with touchscreens; correct?
` A. That's not true.
` Q. Which ones deal with touchscreens?
` A. A large number of them deal with the
`materials and underlying process for touchscreens.
` Q. Do any of them deal with an actual creation
`of a touchscreen?
` A. A complete functional touchscreen?
` Q. Yes.
` A. No.
` Q. Which ones do you believe relate to the
`underlying processes and components of touchscreens?
` A. There is a large number of publications and
`presentations dealing with transparent electronic
`systems, which deals with the underlying materials
`for touchscreens, transparent conductive oxide
`systems.
` Additionally, there are several
`publications and presentations associated with large
`area flexible electronic systems, again dealing with
`touchscreen process technologies.
` Q. So transparent conductors are used in --
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`for electronics components that are not
`touchscreens; correct?
` A. That's true.
` Q. And transparent conductors would be
`materials like indium oxide?
` A. Indium oxide, zinc oxide, indium tin oxide.
`There are several materials that are transparent
`conductors.
` Q. Any transparent insulators that you dealt
`with?
` A. Certainly.
` Q. Which ones?
` A. There is a large number: silicon dioxide,
`alumina, hafnia, zirconia. There is a large number
`of transparent insulators.
` Q. And the other publications that you said
`had something to do with touchscreens would be the
`publications relating to flexible substrates?
` A. Flexible electronics technology.
` Q. Flexible electronics technology.
` So how would flexible electronics
`technology relate to touchscreens?
` A. A lot of the work I have been doing on what
`I call flexible electronics technology is focused on
`developing technologies for fabrication of large
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`Page 10
`area systems, which may or may not be flexible but
`include flexible systems.
` Large areas, for the purposes of this
`definition, would be something that is larger than,
`for example, a typical silicon chip, going from a
`several centimeters on a side to even feet or meters
`on a side.
` Q. And the flexible electronics you believe
`are things that are used in touchscreens?
` A. In some touchscreens, yes. In large area,
`in general, yes. I mean, a touchscreen is, in many
`cases, a large area system.
` Q. You may want to slow down just a little bit
`because the court reporter does have to take down
`what you are saying and you are speaking a little
`bit quickly. So it will probably burn her out if we
`don't slow down a little, just a touch.
` A. I understand. I'll do my best.
` Q. You said that you dealt with processes that
`could be used for making touchscreens; is that
`right?
` A. Correct.
` Q. So in dealing with the processes, that is
`the actual fabrication but not the design of a
`touchscreen; correct?
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` A. I would need you to clarify what you mean
`by "design" versus "fabrication."
` Q. Sure.
` The design would be exactly what the, for
`example, sensors are going to look like, where they
`are going to be placed, where the conduction lines
`are going to be, where the processing circuitry is
`going to be.
` You don't actually design -- you never
`designed the actual layout of how the touchscreen is
`going to be created; correct?
` A. With respect to these publications, that's
`true. That's not true with respect to my
`experience. Your original question was with respect
`to these publications.
` Q. So you don't have any publications in which
`you describe or talk about the actual
`design/creation of the layout of a touchscreen;
`correct?
` A. That's true.
` Q. Now, you said that that's true with respect
`to all of your patents and all of your publications.
` In what situations have you designed the
`layout of a touchscreen?
` A. In my academic work, we actually have
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`projects which we run with the students where we
`actually do make touchscreens for the purposes of
`showing how human-user interfaces work.
` Q. And when was that? When have you done
`that?
` A. Well, I think the first time that I ran a
`class project where students had to deal with touch
`interfaces was probably five or six years ago.
` Q. And what was the nature of the project that
`you were having the students deal with?
` A. There were two aspects to it. The first
`was, we were using the project to illustrate
`concepts associated with circuits that would deduce
`charge; in other words, charge counting circuits.
` The other aspect to it was showing the
`influence of resistor capacitor delays on circuit
`speeds.
` Q. And how did you come up with the -- well,
`did you actually come up with the design for the
`touchscreens or you just left that to your students
`to do?
` A. It's both. I had to come up with a design
`and then assign it as a project to the students, but
`I wouldn't be a very effective teacher if I didn't
`solve the problem first.
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` Q. So what problem were you actually solving
`with respect to the creation of the touchscreen that
`you were assigning to students in class?
` A. I don't understand what you mean by that.
` Q. Well, you said you wouldn't have been a
`very effective teacher if you haven't actually
`solved the problem yourself. So I was inquiring as
`to what problem you were actually referring to.
` A. I understand.
` With respect to that, it was essentially
`developing the layout of the touchscreen and, more
`importantly, developing a circuit to count charge.
` Q. And did you consult any references to
`educate yourself about how to create the layout of
`the touchscreen and how to implement a circuit to
`count charge?
` A. Not specifically for that because I was
`already familiar with the work, but, I mean, in
`general, with respect to my knowledge, yes, I read
`publications all the time.
` Q. So when you sat down to create the
`touchscreen that you assigned as a project for
`students, you didn't have to actually consult any
`materials, you just did it from the top of your
`head?
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` A. Yes.
` Q. Tell me what type of touchscreen you
`actually -- describe the layout of the touchscreen
`that you actually designed for the student project.
` And this was five or six years ago, so that
`would have been like 2009, 2008, 2009?
` A. Correct.
` Q. And that's while you were a professor at
`Berkeley?
` A. Correct.
` Q. Okay. So describe for me the layout of
`that touchscreen.
` A. It had rows and columns of wires and we
`essentially measured capacitive coupling --
`actually, we did charge counting on the columns. We
`drove on the rows and counted on the columns.
` Q. And when you drove on the rows, did you
`drive each row one at a -- serially and then measure
`the charge on the columns serially?
` A. No.
` Q. What did you do?
` A. We drove them simultaneously.
` Q. You drove all the rows simultaneously?
` A. Well, we applied voltages to all the rows,
`yes. We obviously scanned them for purposes of the
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`measurement.
` Q. But when you drove all the rows, you drove
`all the rows at the same time, so you applied
`voltage to all the rows at the same time?
` A. There were no rows that were floating, so
`yes, that's true. Every row had a voltage applied
`to it.
` Q. And it had the same voltage applied to it?
` A. No.
` Q. Why did it have different voltages applied
`to it?
` A. That was part of the project, was to
`show -- was to look at crosstalk effect.
` Q. Describe for me what you mean by that was
`part of the project, to look at crosstalk effects.
` A. There are multiple ways you can drive rows
`in a matrix system. You could, for example, select
`one row, apply a voltage on it while all the other
`rows float, or you can apply specific voltages to
`different rows. So this was to look at the effects
`of those, because depending on what you're adjacent
`rows have, you can impact the parasitics that you
`see in your measurement.
` Q. And when you say the other rows were
`floating, does that mean they were grounded?
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` A. No.
` Q. When they were floating, what does that
`mean?
` A. They were not floating in our system. But
`if they are floating, that means they are
`electrically at a high impedance state with respect
`to an applied potential.
` Q. Can you put that in layman's terms a little
`bit more?
` A. Sure. What that means is, you are not
`trying to apply a voltage on those rows.
` Q. So you're not specifically trying to apply
`a voltage, but there might be some voltage leaking
`from the row that you actually apply to that makes
`it to those?
` A. Unlikely to have significant leakage
`because these are fairly far apart in a touchscreen.
`But, more importantly, because they are floating you
`don't know what their potential is unless you have
`pre-charged them to a particular potential.
` Q. And what was the -- the physical structure
`of the rows and columns? Where were they positioned
`with respect to a substrate?
` A. As I said, they were wires laid over the
`substrate.
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` Q. So they were wires. What was the geometry
`of the wires?
` A. They were rows and columns.
` Q. So just straight rows, straight columns,
`just a wire of uniform thick -- or width or
`thickness?
` A. Correct.
` Q. Were they insulated from one another in any
`manner, the rows and columns?
` A. Yes.
` Q. How were they insulated with one another?
` A. With a polymer.
` Q. So there was a set of rows and then a layer
`of polymer over that set of rows and then another
`set of columns or something such as that?
` A. Conceptually, yes.
` Q. Why did you create a touchscreen system in
`which you had the rows and columns separated by a
`layer of insulation?
` MR. PALYS: Objection; outside the scope
`the scope.
` THE WITNESS: I don't understand what you
`mean by "wire."
`BY MR. BILSKER:
` Q. Why did you pick a design in which you had
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`insulation separating the rows and columns?
` MR. PALYS: Same objection.
` THE WITNESS: I still don't understand. As
`opposed to what?
`BY MR. BILSKER:
` Q. As opposed to putting them all in the same
`surface and just having them crossing each other.
` MR. PALYS: Same objection.
` THE WITNESS: No particular reason. It was
`easy to do using the parts we had.
`BY MR. BILSKER:
` Q. Was that a standard way of creating a
`touchscreen, having an insulation layer between the
`rows and the columns?
` MR. PALYS: Objection; outside the scope of
`direct.
` THE WITNESS: I don't know what you mean by
`"standard way." As I told you, our choice was based
`purely on the parts we had on hand.
`BY MR. BILSKER:
` Q. What was the fabrication process that you
`used to create that touchscreen? Did you just take
`a board and/or a some substrate and lay wires down
`in one direction and then put this polymer material
`over that set of wires and then lay wires orthogonal
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`to those?
` MR. PALYS: Objection; outside the scope of
`direct, relevance.
` THE WITNESS: To be honest, I don't
`remember with respect to that what was the -- how we
`started. That is certainly something that is a
`relatively easy way to prototype a touchscreen, is
`literally by laying wires on it. That's certainly a
`reasonable way to start.
`BY MR. BILSKER:
` Q. Now, you said that one of the things that
`you were testing was the cross capacitance or
`parasitic capacitance when you applied different
`voltages to different rows; correct?
` A. Correct.
` Q. Can you describe for me what you meant by
`that exactly?
` A. Certainly. Depending on how you drive --
`so if you drive a particular row and you are
`measuring or counting charge, for example, on a
`particular column, the charge that you count depends
`on the overall capacitive network formed by that
`system. The overall capacitive network formed by
`that system depends on other rows and columns as
`well.
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` Q. When you designed this system, did you know
`what the effect on the -- the charge counting or
`the, I guess, the capacitance sensing would be by
`charging different rows at different voltages?
` MR. PALYS: Objection; outside the scope of
`direct.
` THE WITNESS: Well, at a conceptual level,
`yes, I had an expectation. I had not measured or
`precalculated what it would be before we did it.
`BY MR. BILSKER:
` Q. And what was your conception of what would
`happen when you charge different rows to different
`voltages as far as the measuring the capacitance?
` MR. PALYS: Same objection.
` THE WITNESS: Since the charge stored on
`parasitic capacitors depends on the voltage between
`the terminals of the capacitor, that affects the
`overall charge balance in the system.
`BY MR. BILSKER:
` Q. Did you think it would make an accurate
`touchscreen device to charge all the rows at
`different voltages?
` MR. PALYS: Objection; form, outside the
`scope of direct, relevance.
` THE WITNESS: I don't know what you mean by
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`"accurate touchscreen."
`BY MR. BILSKER:
` Q. Well, an accurate touchscreen is one that
`is capable of accurately measuring where an object
`is touched on a screen; correct?
` A. You mean it can detect, for example, a
`touch?
` Q. Yes.
` MR. PALYS: Same objection.
` THE WITNESS: If you mean an accurate
`touchscreen for your definition is I can detect
`where a finger is touched, yes. The answer is I
`knew we could design a system that would do that.
`BY MR. BILSKER:
` Q. And you thought you could design a system
`that would do that in a situation where you were
`charging all the rows to different voltages?
` MR. PALYS: Same objection.
` THE WITNESS: Yes.
`BY MR. BILSKER:
` Q. Did you have to take anything specific into
`account when you charged all the rows to different
`voltages?
` MR. PALYS: Objection; outside the scope of
`direct, relevance.
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` THE WITNESS: I don't know what you mean by
`"anything specific into account."
`BY MR. BILSKER:
` Q. When you measured -- so, for example, when
`you measured the charge at each -- you were charging
`the rows or measuring the columns, let's say. When
`you measured the charge at each column, did you have
`to take into account in any fashion what the voltage
`that was on each of those rows?
` MR. PALYS: Objection; outside the scope of
`direct, and relevance.
` THE WITNESS: If your question is on the
`charge counting circuits, in the charge counting
`circuits -- the charge counting circuits were
`designed with the knowledge of what the voltage
`would be on the stimulus.
`BY MR. BILSKER:
` Q. And one of the things that you said was in
`the charge counting circuit where you're measuring
`capacitance, you have to take into account the
`overall electrical characteristics of the network
`that you charged; correct?
` MR. PALYS: Objection; form, outside the
`scope --
` THE WITNESS: I didn't --
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` MR. PALYS: -- of direct.
` THE WITNESS: -- say what you just said I
`said.
`BY MR. BILSKER:
` Q. Did you have to take into account the
`overall system in any way as far as the measurement?
` MR. PALYS: Objection; form, outside the
`scope of direct.
` THE WITNESS: I still don't understand what
`you mean by that question.
`BY MR. BILSKER:
` Q. So in a system where you're charging all
`the rows at the same time to different voltages,
`there are different considerations than when you're
`charging one row at a time to the same voltage;
`right?
` MR. PALYS: Objection; form, outside the
`scope of direct, relevance.
` THE WITNESS: It depends on the context.
`In some situations, that may be true. In others it,
`may not.
`BY MR. BILSKER:
` Q. Well, in this situation where you were
`designing a touchscreen where you charged all the
`rows to different voltages, there was a
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`consideration as to how one row would affect the
`capacitance of another row; correct?
` MR. PALYS: Objection; outside the scope of
`direct, relevance.
` THE WITNESS: Actually, it turned out in
`this particular system the rows were far enough part
`that there was essentially no effect.
`BY MR. BILSKER:
` Q. So -- so you have -- there is a
`consideration as to how far apart the rows are when
`you're charging them -- when you're charging all at
`the same time?
` MR. PALYS: Objection; form, outside the
`scope of direct, relevance.
` THE WITNESS: No, that's not quite what I
`said. What I said is, more generally, the
`capacitance -- parasitic capacitance row to row that
`you see depends on the spacing of the rows.
`BY MR. BILSKER:
` Q. And what is parasitic capacitance?
` A. For the purposes of this discussion where
`we're talking about rows, the parasitic capacitance
`I was referring to was if you are trying to look at
`a particular row, parasitic capacitance would be
`unintended capacitances to other structures. With
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`respect to your question, it would have been with
`respect to other rows.
` Q. And was parasitic capacitance considered a
`good thing, a bad thing, neutral?
` MR. PALYS: Objection; form, outside the
`scope of direct.
` THE WITNESS: It depends on the context.
`It's -- if it's something that's unintended, as long
`as it's manageable, it's relatively neutral. You
`can deal with it, but you have to either deal with
`it or make sure that it doesn't affect you.
`BY MR. BILSKER:
` Q. Well, what do you mean you either deal with
`it or make sure it doesn't affect you?
` I understand the deal with it part, but
`what's the make sure it doesn't affect you part?
` MR. PALYS: Objection; form, outside the
`scope of direct.
` THE WITNESS: In an arbitrary system, if
`there are parasitics that are of a low enough
`magnitude that they have no impact on performance,
`then you can largely ignore them.
` On the other hand, if the parasitics are
`significant, you can account for them and design
`systems that can deal with the parasitics.
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`BY MR. BILSKER:
` Q. And how do you know whether they are going
`to be significant or not significant, the
`parasitics?
` MR. PALYS: Objection; form, outside the
`scope of direct, relevance.
` THE WITNESS: It depends on the context.
`You could, for example, take advantage of geometry
`to ensure that they just physically will be small
`enough that you can ignore them. You can take
`advantage of material properties or be aware of
`material properties and use that to drive
`calculations that will then allow you to derive
`values. You can perform electromagnetic or
`electrostatic simulations to calculate approximately
`what those values will be or you can do physical
`measurements.
`BY MR. BILSKER:
` Q. So you've got to do some experimentation to
`know whether the parasitics are going to adversely
`affect your measuring system?
` MR. PALYS: Objection; form, outside the
`scope of direct relation.
` THE WITNESS: No, that's not necessarily
`true.
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`BY MR. BILSKER:
` Q. In situations is it not true?
` MR. PALYS: Same objections.
` THE WITNESS: It's the situation I gave you
`to start. In other words, in a situation where you
`know just based on your layout that the -- and the
`material properties that the parasitics will be
`small enough that you can ignore them.
`BY MR. BILSKER:
` Q. And that's a situation where you have the
`rows spaced far apart?
` MR. PALYS: Same objections.
` THE WITNESS: That is one situation. It's
`not the only situation.
`BY MR. BILSKER:
` Q. What other situation?
` MR. PALYS: Objection; form, outside the
`scope of direct, and relevance.
` THE WITNESS: Any situation where the
`parasitic capacitances are small enough that they
`don't affect your ability to localize finger
`position.
`BY MR. BILSKER:
` Q. And how are you going to know when they're
`small enough without doing some form of
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`experimentation?
` MR. PALYS: Objection; form, outside the
`scope of direct, and relevance.
` THE WITNESS: You don't need to necessarily
`do experiments to -- it depends on the context. In
`some cases, you may need to do experiments. In
`other cases, just based on the physical layout
`and the -- sorry.
` In some cases, you may need to do
`experiments. In other cases, based on the physical
`layout and material properties, you may be able to
`just calculate with a first order of calculation
`that it's not a concern.
`BY MR. BILSKER:
` Q. All right. So when I use the word
`"experimentation," I'm including an actual physical
`measurement, as well as a simulation or calculation.
` So in what situations will you not have to
`do either a physical measurement or a calculation to
`determine whether the parasitics are going to
`adversely affect you?
` MR. PALYS: Objection; form, outside the
`scope of direct, and relevance.
` THE WITNESS: I don't know how you're
`limiting "calculation." If calculation could be a
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`quick, back-of-the-envelope estimate that you just
`do in your head, well, you always -- as an engineer,
`you're always at least doing sort of
`back-of-the-envelope estimates in your heads. That
`doesn't qualify as experimentation necessarily. It
`depends on the context.
`BY MR. BILSKER:
` Q. In what situations do you know that the
`physical layout is going to provide a situation in
`which the parasitics are not going to be a problem?
` Is that, for example, a situation when you
`have the conductor elements that are orthogonal to
`one another insulated by a layer?
` MR. PALYS: Objection; form, outside the
`scope of direct.
` THE WITNESS: I would need more context to
`answer that question.
`BY MR. BILSKER:
` Q. Well, you said in some situations the
`physical layout of the system will lead you to the
`conclusion that parasitics are not going to be an
`issue. What physical layouts did you have in mind?
` MR. PALYS: Same objection.
` THE WITNESS: There are multiple
`possibilities. If -- our discussion was
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`specifically related to capacitance row to row. If
`the rows are far enough apart, then you may be in a
`position where you can say I don't need to worry
`about parasitics.
`BY MR. BILSKER:
` Q. And how do you know when the rows are far
`enough apart?
` MR. PALYS: Objection; form, outside the
`scope of direct, relevance.
` THE WITNESS: It depends, again, on
`context. For example, if the spacing between the
`rows is large enough that you can estimate that any
`capacitance that exists row to row does not perturb
`your ability to count charge on the columns, that
`would be a situation where you may say: I can
`ignore the parasitics.
`BY MR. BILSKER:
` Q. But how do you know that they're far enough
`apart?
` MR. PALYS: Same objections.
` THE WITNESS: Again, it depends -- as I
`just said, it depends on the geometry and it depends
`on what you estimate, and it depends on material
`properties, obviously.
`//
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`BY MR. BILSKER:
` Q. In the system that you designed, did you
`know that the rows were far enough apart that the
`parasitics would not be a problem?
` MR. PALYS: Objection; outside the scope of
`direct, and relevance.
` THE WITNESS: Yes, I believe so. This was
`a big system with widely spread rows.
`BY MR. BILSKER:
` Q. When you say "widely spread," what do you
`mean?
` MR. PALYS: Same objections.
` THE WITNESS: Widely spread in that
`situation was several millimeters apart.
`BY MR. BILSKER:
` Q. Aside from this one system that you
`assigned to your students in 2008, 2009, what other
`touchscreens had you designed?
` A. Again, you mean complete touchscreen
`systems?
` Q. Yes.
` A. I have not.
` Q. And this system that you designed in 2008
`or 2009, that was a multilayer touchscreen system;
`correct?
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` MR. PALYS: Objection; form.
` THE WITNESS: Could you define what you
`mean by "multilayer" for me, please?
`BY MR. BILSKER:
` Q. Sure. The rows and columns were in
`different planes.
` A. Yes, that's true.
` Q. Did you ever design a system in which the
`rows and columns of conductors were in the same
`plane?
` A. A touchscreen system?
` Q. Yes.
` A. And a complete touchscreen system?
` Q. Yes.
` A. No, I have not.
` Q. So you've never encountered on your own any
`of the particular problems that may arise in
`creating a touchscreen where the rows and the
`columns are on the same plane; correct?
` MR. PALYS: Objection; form.
` THE WITNESS: No, that's not
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