Transcript of DR. PHILLIP WRIGHT
`
`Date: April 30, 2015
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`Case: LG ELECTRONICS, INC., ET AL v. CYPRESS SEMICONDUCTOR
`CORP.
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`Planet Depos
`Phone: 888-433-3767
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`Worldwide Court Reporting | Interpretation | Trial Services
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`Exhibit 2017 - Page 01 of 44
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`

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`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`--------------------------------x
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`LG ELECTRONICS, INC., LG :
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`ELECTRONICS U.S.A, INC., and :
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`LG ELECTRONICS MOBILECOMM : Cases
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`U.S.A., INC., : IPR2014-01302 - Patent 8,059,015
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` Petitioner, : IPR2014-01342 - Patent 8,004,497
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` v. : IPR2014-01343 - Patent 8,519,973
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`CYPRESS SEMICONDUCTOR CORP., :
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` Patent Owner. :
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`--------------------------------x
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`
`
` Deposition of DR. PHILLIP WRIGHT
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` Washington, DC
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` Thursday, April 30, 2015
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` 8:58 a.m.
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`1 (Pages 1 to 4)
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`3
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` A P P E A R A N C E S
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` ON BEHALF OF PETITIONER:
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` BRIAN A. TOLLEFSON, ESQUIRE
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` SOUMYA P. PANDA, ESQUIRE
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` ROTHWELL, FIGG, ERNST & MANBECK, P.C.
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` 607 14th Street, NW
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` Suite 800
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` Washington, DC 20005
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` (202) 783-6040
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` ON BEHALF OF PATENT OWNER CYPRESS SEMICONDUCTOR CORP:
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` JEFFREY A. MILLER, ESQUIRE
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` KAYE SCHOLER, LLP
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` Two Palo Alto Square
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` 3000 El Camino Real
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` Suite 400
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` Palo Alto, California 94306
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` (650) 319-4500
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` C O N T E N T S
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`EXAMINATION OF DR. PHILLIP WRIGHT PAGE
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`4
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` By Mr. Miller 6
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` By Mr. Tollefson 144
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` By Mr. Miller 154
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` E X H I B I T S
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` (Marked during the deposition and attached to the
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` transcript.)
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`EXHIBIT NUMBER PAGE
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` Exhibit 2014 Figure 7 of the '388 patent as
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` annotated by Dr. Wright 93
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` Exhibit 2015 Figure 7 of the '388 patent as
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` annotated by Dr. Wright 106
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` Exhibit 2016 Figure 7 of the '388 patent as
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` annotated by Dr. Wright 108
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`Job No.: 81268
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`Pages: 1 - 161
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`Reported By: Rebecca Stonestreet, RPR, CRR
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` Deposition of DR. PHILLIP WRIGHT, held at the
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`offices of:
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` ROTHWELL, FIGG, ERNST & MANBECK, P.C.
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` 607 14th Street, NW
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` Suite 800
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` Washington, DC 20005
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` (202) 783-6040
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` Pursuant to agreement, before Rebecca Stonestreet,
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`Registered Professional Reporter, Certified Realtime
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`Reporter, and Notary Public in and for the District of
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`Columbia, who officiated in administering the oath to
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`the witness.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Exhibit 2017 - Page 02 of 44
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`

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`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
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` E X H I B I T S C O N T I N U E D
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` (Exhibits previously marked and referred to in the
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` deposition.)
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`EXHIBIT NUMBER PAGE
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` Exhibit 1001 U.S. Patent No. 8,059,015 73
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` Exhibit 1002 U.S. Patent No. 5,463,388 26
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` Exhibit 1008 U.S. Patent No. 5,543,588 39
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` Exhibit 1011 Prosecution history for Patent
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` No . 8,059,015 78
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` Exhibit 1012 U.S. Patent No. 7,844,914 112
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` P R O C E E D I N G S
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`understand, you need to tell me and I'll do what I can to
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`try to clarify. Can you do that for me?
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` A Yes, I can.
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` Q And another sort of ground rule is that
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`Rebecca, I'm sure, is a terrific court reporter, but
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`there's no court reporter on earth who can record
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`testimony if multiple people are speaking at the same
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`time. So I would appreciate it if you would let me
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`finish my question, and I will do my best to allow you to
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`answer.
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` I can almost promise you that I will fail at
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`that admonition at some point today, but we should do our
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`best to work with the court reporter on that. Is that
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`okay?
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` A Okay.
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` Q Are you under any medication that would
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`prevent you from testifying truthfully today?
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` A No.
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` Q Great. Do you recall when you were retained
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`to testify in this matter?
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` A I believe my engagement, my first period of
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`engagement, began in December of 2013, is when I was
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` (DR. PHILLIP WRIGHT, having been duly sworn, testified as
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` follows:)
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` EXAMINATION BY COUNSEL FOR PATENT OWNER
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` CYPRESS SEMICONDUCTOR CORP.
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`BY MR. MILLER:
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` Q Good morning, Dr. Wright. My name is Jeffrey
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`8 Miller, I represent Cypress Semiconductor in the
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`inter partes review proceeding that we're here to discuss
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`your declaration on. Have you ever given your deposition
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`before?
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` A This is my first.
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` Q Well, I'm sure you spent some time working
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`with your lawyers to help you get ready. I may ask you
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`about that. I'll briefly tell you the way I think it's
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`going to work today, and if you have any questions,
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`please let me know.
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` So I'm going to ask you a series of questions,
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`and you're required to answer those questions unless your
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`lawyer tells you not to. Do you understand that?
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` A Yes.
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` Q If I ask you a question that you don't
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`first contacted.
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` Q And who contacted you?
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` A Jason Shapiro here at the -- Rothwell & Figg.
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` MR. TOLLEFSON: I just want to caution you not
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`to reveal the substance of any conversations with anyone
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`from Rothwell Figg.
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` Q And starting from your first retention at the
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`end of 2013 up until now, do you know how many hours
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`you've put into working on this matter?
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` A I don't have the exact number in mind, no.
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` Q Can you give me an approximate number?
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` A Not a very accurate one without checking my
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`billing records. But I can roughly add up the number
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`very approximately.
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` MR. TOLLEFSON: I'm going to object to the
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`form of the question.
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` Q You can still answer, even though your lawyer
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`has objected to the form of the question.
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` A I would be coming up with a very approximate
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`number.
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` Q Is it more than 100 hours?
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` A It's more than 100.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 2017 - Page 03 of 44
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`

`
`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
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`3 (Pages 9 to 12)
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` Q Is it more than 200 hours?
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` A I don't think so.
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` Q And you prepared, I believe, three
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`declarations?
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` A Correct. Here in front of me.
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` Q I have copies for you as well.
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` A All right.
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` Q And do you know approximately how many hours
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`you put into the preparation of all three of those
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`declarations?
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` A Well, it would have been a subset of the total
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`amount with the upper limit that you set, and no more.
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` Q I'm going to provide you with copies of your
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`declaration. The first one I'll give you is the
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`declaration that was filed in the IPR proceeding relating
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`to U.S. patent 8,519,973, and that is Exhibit 1010 in
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`that proceeding.
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` Next I'm going to give you a copy of
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`Exhibit 1010 in the IPR proceeding relating to U.S.
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`patent 8,004,497.
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` MR. TOLLEFSON: Jeff, are you going to
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`revise them, exam them further. Yes.
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` Q Which lawyers were those lawyers?
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` A Principally Soum [sic] and Mike Jones.
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` Q And do you remember the time, approximately
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`how long -- and I'm not talking about hours billed, but
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`timeframe --
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` A Timeframe?
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` Q -- from September to July, you know, or
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`something like that?
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` A They had a due date. I don't remember the
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`exact due date. I think it was in mid year 2014. And
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`having a due date, we commenced work over a period of
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`some weeks. But again, I would have to check my billing
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`records if you wanted an accurate tally.
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` Q Now, each of the declarations you've prepared
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`for the respective IPRs refers to some prior art
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`references.
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` A Right.
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` Q Who filed those prior art references?
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` MR. TOLLEFSON: I'm going to object. I'm
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`going to object on the grounds of privilege and instruct
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`you not to answer.
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`separately mark these since they're both exhibits?
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`them. I've been through this before, and it's actually
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`easier if you just go -- I'll talk to the witness about
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`it but there's no need to separately mark them.
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` Q And finally, I'm going to give you what's been
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`6 marked as Exhibit 1010 in the IPR proceeding relating to
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`U.S. patent 8,059,015.
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` Now, as your counsel alluded to, there are
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`three different proceedings with three different case
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`numbers. And you filed a declaration in each, and they
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`all bear the Exhibit 1010 label.
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` So when I ask you about particular statements
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`you made in a particular declaration, I'm going to
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`clarify which proceeding it related to, and I would
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`appreciate it if you could do the same for me as well.
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` A Say, by the last three digits of the patent
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`number?
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` Q Sure. So '497, '973, '015.
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` Who wrote these declarations?
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` A I did.
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` Q Did you have any help from the lawyers?
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` A I worked with the lawyers to draft them,
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` THE WITNESS: Okay.
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` Q Are you going to follow your counsel's advice
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`or instruction?
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` A Yes.
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` Q Do you recall when the first time was you saw
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`the prior art reference U.S. patent 5,463,388, the
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`inventor being Mr. Boie?
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` MR. TOLLEFSON: Objection to form.
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` Q You can still answer.
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` A I don't think I have to.
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` Q Why?
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` A Because I was advised not to, I should say.
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` MR. TOLLEFSON: No, I didn't advise you not
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`to. I objected to form because it was a yes or no answer
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`and I think he was trying to ask you a date. So I just
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`objected to form.
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` Q Let me rephrase and maybe that will solve the
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`problem.
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` Do you recall when the first time was you saw
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`U.S. patent 5,463,388, with the first named inventor
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`being Robert A. Boie?
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` MR. TOLLEFSON: Objection to form.
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`PLANET DEPOS
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`Exhibit 2017 - Page 04 of 44
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`

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`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
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` Q You can still answer.
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` A I don't recall the date in detail.
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` Q Was it before or after you were retained in
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`this matter?
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` A I believe it was after.
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` Q Thank you.
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` How about U.S. patent 5,543,588 to
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`Stephen Bisset, et al. Do you recall what the first time
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`you saw that patent was?
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` A No, not precisely.
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` Q Was it before or after you were retained in
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`this engagement?
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` A I don't know.
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` Q And how about do you recall when the first
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`time you saw U.S. patent 7,844,914, issued to
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`Bartley Andre, et al.?
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` MR. TOLLEFSON: Objection to form.
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` A I don't recall in detail, no.
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` Q Was it before or after you were retained in
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`this matter?
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` A I believe it was after.
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`declaration that you prepared in the IPR proceeding
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`relating to the '973 patent.
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` A (Witness complies.)
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` Q And you attached an Exhibit A to the
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`declaration, which is your CV. Could you turn to that,
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`please?
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` A (Witness complies.)
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` Q In the third page of your CV you list your
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`educational background.
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` A Correct.
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` Q And your CV says that you obtained a
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`bachelor's, a master's, and a Ph.D. in electrical
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`engineering?
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` A The bachelor's at Purdue is in engineering.
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` Q I apologize.
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` A And the Ph.D. and M.S. were from the
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`University of Illinois in electrical engineering,
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`correct.
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` Q Was there any specific research area that you
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`focused on in your studies?
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` A Not until I was a graduate student.
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` Q When you were a graduate student, what was
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` Q When was the first time you saw U.S. patent
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`7,821,502, to Hristov?
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` MR. TOLLEFSON: Objection to form.
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`your focus of study?
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` A My focus of study was the semiconductor
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` A Could you restate the question?
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`3 materials and electronic device structures that are used
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`BY MR. MILLER:
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` Q What don't you understand about it?
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` A Could you just repeat the question? I've been
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`distracted from the question. Just simply repeat it,
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`please.
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` Q When was the first time you saw U.S. patent
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`7,821,502, which issued to Luben Hristov?
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` A I don't recall the exact date.
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` Q Was it before or after you were retained in
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`this matter?
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` A It was after.
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` Q When was the first time you saw U.S. patent
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`4,242,676, which was issued to Christian Piguet, et al.?
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` A I don't recall the exact date.
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` Q Was it before or after you were retained in
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`this matter?
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` A I believe it was after.
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` Q I have some questions about your background.
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`If you could pull out Exhibit 1010, which is your
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`in light emitting diodes and lasers.
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` Q After you graduated with your Ph.D., it looks
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`like you went to go work for Varian in Palo Alto?
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` A Uh-huh.
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` Q What were your responsibilities at Varian?
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` A My title was as an engineer there in the
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`corporate research laboratory. And that answers the
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`question.
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` Q Any particular research area?
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` A I was again, as it states here, working on
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`semiconductor materials and devices for light emitting
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`diodes and semiconductor lasers.
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` Q And looking at your CV, it looks like you left
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`Varian and went to work for Bell Labs?
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` A Uh-huh.
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` Q Looks like you were there for quite a while,
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`with several different titles. Can you give me a brief
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`overview of what your areas, your technical areas of
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`responsibility were?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 2017 - Page 05 of 44
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`

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`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
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` A Well, as a member of technical staff there, I
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`continued to develop, among other types of electronic
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`devices, semiconductor lasers that were used in the first
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`transatlantic fiber optic cable communications system.
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` Q So that was as a member of technical staff?
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` A Correct.
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` Q Then you became a technical supervisor?
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` A Right. And my work somewhat generalized as I
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`that company?
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` A Yes.
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` Q What types of work did Martin Kestrel do?
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` A I established Martin Kestrel to provide
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`engineering services to essentially the global suppliers
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`of what are called epitaxial layers that are used in the
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`fabrication of electronic devices, specifically
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`heterojunction bipolar transistors and high electron
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`9 managed people. And I stayed at Bell Laboratories in a
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`9 mobility transistors. These are electronic devices with
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`supervisory role through the Bell system divestiture in
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`1984, which is when I became, in the new organization
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`that was divested, a district research manager.
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` Q And again, that was in lasers and photonics
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`and whatnot?
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` A Communication systems, telecommunications
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`systems essentially for telephone calls.
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` Q And then it looks like in 1984 you left
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`Bell Labs to work for Lytel Incorporated?
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`very high levels of performance at high frequencies.
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` Q And then in 1993 you joined Motorola?
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` A Yes.
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` Q What happened to your company? Did it get
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`bought by Motorola?
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` A No. It was a very small company. I had at
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`times one employee, and I became dissatisfied that I
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`could only grow the business so large because it was
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`so -- such a niche. And I had the opportunity to join
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` A Yes.
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`19 Motorola, so I did so.
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` Q What sorts of technical work did you perform
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`at Lytel?
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` A I began as the director of process
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` Q What types of work did you do at Motorola?
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` A I managed a group involved in developing and
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`applying display technologies, which were initially based
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`development, and basically put in place all of the
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`staffing facilities for making these electronic devices.
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`And my responsibility extended to the component level,
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`and my other colleagues worked to assemble them into
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`5 modules and electronic circuits and the like.
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` Q And it looks like in 1987 you then joined
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`Ford Microelectronics?
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` A Yes.
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` Q What types of technical work did you perform
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`at Ford?
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` A There I was a manager of -- essentially a
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`program manager and managed some personnel in the
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`development of not optical, or optoelectronic components,
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`but electronic components and circuits based on
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`heterojunction bipolar transistors.
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` Q And looks like you were at Ford for about
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`three years and then you moved on to the Martin Kestrel
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`company?
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` A Yes.
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` Q Is that right?
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` A Yes.
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` Q According to your CV, you were the founder of
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`on some of the same materials and device types of light
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`emitting diodes, but evolved into the development of
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`display technology and display applications using a range
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`of displays including liquid crystal displays, and
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`eventually moved into applications research.
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` Motorola was a big cell phone producer, and
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`application research essentially in portable consumer
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`electronic products.
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` Q You were at Motorola for about five years, and
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`then you joined AMP?
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` A Yes.
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` Q A-M-P?
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` A A-M-P, yes.
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` Q What did you do there?
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` A I joined AMP to manage two groups at two
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`different locations that were involved in the development
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`of optical components and electronic subsystems using
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`those components, the packaging and the assembly into
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`circuits.
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` Q And then you joined Corning?
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` A Yes.
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` Q What did you do there?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 2017 - Page 06 of 44
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`

`
`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
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`6 (Pages 21 to 24)
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` A At Corning I was a program director of a
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`fairly large-scale optical switch project that involved
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`the technology and the electronic systems required to
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`switch optical -- signals from optical fibers and route
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`them from one fiber to another at will.
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` Q And then according to your CV you joined
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`7 Momentum Technology Partners in 2002. What did you do
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`there?
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` A In 2002, I began my career essentially as a
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`sole practitioner, as a technical consultant. Momentum
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`Technology Partners was a loose affiliation of
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`like-minded people that cooperated to exchange ideas and
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`opportunities.
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` Q Did you work on optical technologies when you
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`were at Momentum?
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` A You know, I worked on client projects as they
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`dictated the subject matter. One of them, I think,
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`that's mentioned here was a print -- was an electrical
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`printed circuit board manufacturer who wanted to combine
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`with his electrical circuits embedded optical waveguides.
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` Another engagement I worked, to show the
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`variety, I worked with -- as mentioned here, I worked
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` A Yes.
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` Q Was that effectively just a renaming of your
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`independent consulting?
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` A Yes. Essentially I'm still a sole
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`practitioner. I sometimes ally with other associates
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`that pool together into flexible teams, and WRT
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`Associates was aimed at branding and formalizing my
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`consulting business.
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` Q And what types of technical consulting have
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`you done while associated with WRT?
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` A I've worked in a number of areas, some of it
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`related to optics and optoelectronics, such as looking
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`at -- one client had asked me to provide him some
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`information about the market prospects for semiconductor
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`lasers to use in pico projectors, for example, that are
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`used in a mobile handset.
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` And another example would be working with a
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`display metrologist on a client's need to understand the
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`performance of a display in his mobile device
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`application.
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` Q Okay. So it looks like you got a Ph.D. in
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`about 1977 and have been working in the technical field
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`with a company based in the U.K., outside of Edinburgh,
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`that was interested in establishing a small business high
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`tech incubator for new business development based --
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`actually, it was in an old Motorola facility.
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` Q And then in 2004, according to your CV, it
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`says independent consultant. Can you tell me what that
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`was about?
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` A Yeah. Yes. As it says here, again, I
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`continued to work in a consulting role on various client
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`projects. When I moved to Colorado, I worked with some
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`colleagues I knew in Colorado to look at new small
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`business opportunities in electronic devices for medical
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`applications. I worked with a Washington-based trade
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`association called the Optoelectronics Industry
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`Development Association, and specifically covered topics
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`such as use of optoelectronics in wireless devices,
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`17 mobile handsets, and the like.
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` And so essentially whatever my client asked me
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`to do, if I could be responsive, I would have done a
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`variety of projects along those lines.
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` Q And then it looks like in 2007 you founded
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`22 WRT Associates?
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`for almost 30 or more years. Did I do my math right
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`there?
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` A It's probably longer, but let's not belabor
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`that. But at least 30 years.
`
` Q Okay. So going to your declaration, I believe
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`in here you -- and we're looking at Exhibit 1010 in the
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`'973 proceeding, but I believe your opinion at this
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`portion I'm going to refer to is the same in all three of
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`your declarations. But you can confirm that if you want
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`to. But in paragraph 26 of your declaration, it's on
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`page 7 --
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` A Paragraph 26, I'm sorry.
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` Q Paragraph 26 on page 7.
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` Towards the end of paragraph 26 in
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`Exhibit 1010 you provide an opinion of what the level of
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`ordinary skill in the art is. Do you see that?
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` A Uh-huh. Yes.
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` Q And I'm paraphrasing here, but your opinion is
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`that a person having ordinary skill in the art would have
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`a bachelor's degree in electrical engineering with one to
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`two years of design experience or comparable educational
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`experience. Do you see that?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 2017 - Page 07 of 44
`
`

`
`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
`
`25
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`7 (Pages 25 to 28)
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` A Yeah. It reads, "at least a bachelor of
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`science in electrical engineering, with one to two years
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`of design experience or a comparable amount of combined
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`education and equivalent industry experience in the
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`electronic and sensor design field."
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` Q And from going through your experience, both
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`educational and industry, it looks like you have far in
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`excess of what you believe to be the level of ordinary
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`skill. Is that right?
`
` A Yes.
`
` Q So would you classify yourself as a person
`
`having extraordinary skill in this art?
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` MR. TOLLEFSON: Objection to form.
`
` Q You can answer if you can.
`
` A Well, my resume' kind of speaks for itself as
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`far as what my preparation by way of education and
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`experience is.
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` Q And that's a lot more than what the ordinary
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`diagram showing the relationship between the position of
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`a user's finger and the capacitances at electrodes in a
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`two-dimensional sensor constructed in accordance with his
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`invention.
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` Q And in Boie there's an item labeled 101, which
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`looks to be some kind of a 4x4 array of something. Do
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`you see that?
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` A Yes. That's representative. That's a
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`schematic representation of his electrode array.
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` Q How many electrodes are shown in that
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`electrode array?
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` A Because there's a 4x4 matrix with 16 squares
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`there, it suggests that there are 16 electrodes arranged
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`in some fashion in the array 101.
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` Q Thank you. And then towards the bottom end of
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`Figure 1 of Boie, what is shown there?
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` A The histogram, the two-dimensional histogram
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`at the base of the figure is what you're referring to
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`level of skill is. Right?
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`19 marked -- kind of labeled 110?
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` MR. TOLLEFSON: Objection to form.
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` A I repeat what I said before, that -- it's all
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`there in the record.
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` Q Yes.
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` A The two-dimensional histogram shows the
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`capacitance values that are observed in response to a
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` Q Thank you. I'm going to provide you with a
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`copy of U.S. patent 5,463,388, which has been marked as
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`1
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`2
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`finger approaching the electrode array 101.
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` Q It looks like in Boie there appears to be a
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`Exhibit 1002 in all three IPR proceedings. This is the
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`3 measured capacitance on multiple of those electrodes. Do
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`Boie patent.
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` So would it be okay with you if I refer to
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`this patent as Boie, or the Boie patent?
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` A Yes.
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` Q Thank you. This is one of the patents that
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`you referred to in all three of your declarations.
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`Right?
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` A Yes.
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` Q When you were preparing your declaration, do
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`you recall how much of the Boie patent you reviewed?
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` A Yes.
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` Q And how much of it did you review?
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` A The whole patent.
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` Q If you could turn, please, to Figure 1 of the
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`Boie patent, Exhibit 1002.
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` A (Witness complies.)
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` Q Can you explain to me what's shown in Figure 1
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`of Boie?
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` A Yes. So Boie describes it as a graphic
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`I understand that correctly?
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` A The various electrodes respond to a varying
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`degree to the localized presence of the finger or
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`conductive object on the electrode array.
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` Q And there's a point marked as reference
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`numeral 111. Do you see that?
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` A Yes.
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` Q Can you tell me what that is?
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` A I believe Boie describes it as the xy position
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`of the coordinates of the centroid calculated from the
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`various capacitance values over the array in response to
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`the finger touching the array.
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` Q What's your understanding of what a centroid
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`is?
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` A Boie lays out the calculation of the centroid.
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`But in essence it's an averaging of the response in the
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`two dimensions shown over space to a resolution affected
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`by the number of measuring segments; here in this case,
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`16.
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`PLANET DEPOS
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`
`Exhibit 2017 - Page 08 of 44
`
`

`
`DEPOSITION OF DR. PHILLIP WRIGHT
`CONDUCTED ON THURSDAY, APRIL 30, 2015
`
`29
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` Q And in the electrode array in Boie, do you
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`know what the resolution of that sensor is?
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` A Not by looking at the schematic diagram.
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` Q Can it resolve -- well, let's back up a little
`
`bit.
`
` I believe you said that it reports an xy
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`position of coordinates. Let me ask that again.
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` I believe you testified a few minutes ago that
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`Boie reports an xy position of the coordinates of where
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`state of the array without a finger or other object being
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`nearby, accordingly, it may be desirable to repeat step
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`601 a number of times and then to select the minimum
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`capacitance values read as the initial values, thereby
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`compensating for the effect of any objects moving close
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`to array during the initialization step."
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` "After initialization, all capacitance values
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`are periodically read and the initial values subtracted
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`to yield a remainder value for each element. If one or
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`the conductive object is placed on the sensor. Do I have
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`10 more of the remainders exceeds a preset threshold,
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`that right?
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` A Not exactly.
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` Q Well, what exactly does Boie report?
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` A Boie --
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` MR. TOLLEFSON: Objection to form.
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` Q You can answer.
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` A Could you ask the question again?
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` Q You testified that Boie calculates a centroid
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`of the conductive object placed on its electrode array.
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`Right?
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` A Yes.
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` Q And how is that centroid calculation reported?
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`indicating that an object is close to or touching the
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`array, then the x coordinates [sic] of the centroid of
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`capacitance for such object can be calculated from such
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`remainders. For applications in which the electrodes of
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`array 100 are connected in rows and columns, as shown in
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`Figure 2 and 3, the calculation can be performed as
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`follows."
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` And Boie provides two formulas for the
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`calculation of the x and y values respectively, of the
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`coordinates of the centroid. And then he explains in
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`those equations that you -- so x is the number of
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`columns. Capital V of nx is a remainder value for column
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` MR. TOLLEFSON: Objection to form.
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` A I don't understand the question about how it's
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`reported.
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` Q Well, let me ask you this: The centroid
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`calculation in Boie reports an xy position of the
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`conductive object on the electrode array. Right?
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` MR. TOLLEFSON: Objection to form.
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` A We can read the patent. Boie lays out what he
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`lays out in the patent.
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` Q So do you disagree with me that Boie -- does
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`Boie not report an xy position of a --
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` A I just don't quite understand what you mean by
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`"report."
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` Q Well, what's -- so we've established that Boie
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`calculates the centroid of the conductive object on the
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`electrode array. Right?
`
` A Boie, in Column 5, beginning, for example, at
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`Line 10, states, referring to Figure 6, which is a figure
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`referring to the use of this as a computer mouse, it
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`says: "Microcomputer 406 reads the initial capacitance
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`values for all the elements in the array 100 and stores
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`such values. Such initial values should reflect the
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