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` UNITED STATES PATENT AND TRADEMARK OFFICE
` PATENT TRIAL AND APPEAL BOARD
`
`SONY CORPORATION, SAMSUNG )
`ELECTRONICS CO., LTD., )
`SAMSUNG DISPLAY CO., LTD., )
` )
` Petitioners, )
` )
` vs. ) Case No.
` ) IPR2015-00863
`SURPASS TECH INNOVATION, )
`LLC, )
` )
` Patent Owner. )
`------------------------- )
`
` January 27, 2016
` 10:03 a.m.
`
` Deposition of WILLIAM K. BOHANNON, held
` at the offices of Kenyon & Kenyon LLP, One
` Broadway, New York, New York, before Laurie A.
` Collins, a Registered Professional Reporter
` and Notary Public of the State of New York.
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`212-279-9424
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 1
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`Page 2
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`Page 4
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`W I L L I A M K. B O H A N N O N ,
`3 called as a witness, having been duly sworn
`4 by the notary public, was examined and
`5 testified as follows:
`6 EXAMINATION BY
`7 MR. HANLEY:
`8 Q. Good morning, Mr. Bohannon.
`9 A. Good morning.
`10 Q. Would you just state your full name and
`11 your residence address, please?
`12 A. William K. Bohannon, and I live at 216
`13 Woodland Star Circle in Whitefish, Montana.
`14 Q. Now, I'm going to show you a document
`15 that's labeled petitioner's notice of deposition
`16 of William K. Bohannon, and it's something that we
`17 on behalf of the petitioners have filed in the
`18 patent office.
`19 MR. HELGE: I'm sorry, do we need to go
`20 around the room and introduce ourselves?
`21 THE REPORTER: Not for my purposes.
`22 Q. So I'll just note, Mr. Bohannon, that I
`23 read the title. It relates to case IPR2015-00863,
`24 patent number 7,202,843. Do you see that?
`25 A. Yeah.
`
`A P P E A R A N C E S:
`
`1 2
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`3 4
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` KENYON & KENYON LLP
`5 Attorneys for Petitioner Sony
`6 One Broadway
`7 New York, New York 10004
`8 BY: WALTER E. HANLEY, JR., ESQ.
`9 whanley@kenyon.com
`10 MICHELLE CARNIAUX, ESQ.
`11 mcarniaux@kenyon.com
`12
`13 COVINGTON & BURLING LLP
`14 Attorneys for Petitioner Samsung
`15 850 Tenth Street, N.W.
`16 Washington, D.C. 20001-4956
`17 BY: PAUL J. WILSON, ESQ.
`18 pwilson@cov.com
`19
`20 DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
`21 Attorneys for Patent Owner
`22 8300 Greensboro Drive, Suire 500
`23 McLean, Virginia 22102
`24 BY: WAYNE HELGE, ESQ.
`25 whelge@dbjg.com
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`Page 3
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`Page 5
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`1 Bohannon
`2 Q. And have you seen this petitioners'
`3 notice of petition before?
`4 A. No, but Wayne told me about it.
`5 Q. Do you understand at least that you're
`6 appearing here today pursuant to the notice that
`7 we provided that you're looking at right now?
`8 A. Excuse me, what was the question?
`9 Q. Do you understand you're appearing --
`10 A. Yes, I'm here.
`11 Q. -- in response to this notice?
`12 A. Yes, not for a vacation.
`13 And you must be Michelle Carniaux?
`14 MS. CARNIAUX: Yes.
`15 THE WITNESS: Because I see you signed
`16 it.
`17 Q. And you also understand that the patent
`18 that this proceeding relates to is the '843
`19 patent?
`20 A. Yeah.
`21 Q. And this proceeding is IPR2015-00863?
`22 A. Yes.
`23 Q. Have you testified either at a trial or
`24 at a deposition previously?
`25 A. Yes.
`
`A P P E A R A N C E S (continued):
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`12
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`34
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`ALSO PRESENT:
`5 THOMAS L. CREDELLE
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`6789
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`10
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 2
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`1 Bohannon
`2 Q. And approximately how many times?
`3 A. Oh, maybe about a dozen.
`4 Q. And does that dozen include any actual
`5 trial testimony?
`6 A. Not in a -- not in a trial. I
`7 testified in front of a three-judge, you know,
`8 arbitration process once, which is probably the
`9 closest to a trial. The other times it was just
`10 this kind of situation.
`11 Q. And this kind of situation is a
`12 deposition?
`13 A. Yeah.
`14 Q. So I gather, then, I don't need to
`15 explain in great detail what's going to happen
`16 here today, so I will do that. I will also
`17 surmise that Mr. Helge probably gave you some
`18 briefing on what a deposition is about.
`19 I just want to go over a couple of
`20 things. One is that we have a court reporter
`21 sitting here who's going to be taking down
`22 everything that is said. And I will be asking you
`23 questions, and you will be responding to the
`24 questions. What I'd ask you to do is allow me to
`25 complete my question before you begin your answer.
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`1 Bohannon
`2 A. Yes, I understand.
`3 Q. So when we take periodic breaks, which
`4 we will do, you're not to confer with Mr. Helge
`5 regarding your deposition testimony?
`6 A. Yes, I understand.
`7 Q. And during our lunch break you
`8 understand you are not to confer with Mr. Helge
`9 regarding your testimony?
`10 A. Yes, I understand that part.
`11 Q. When I conclude my questioning and if
`12 Mr. Helge decides he wants to ask you some
`13 questions, do you understand you're not to confer
`14 with him concerning the questions he might want to
`15 ask you?
`16 A. Yes, I understand.
`17 Q. Your connection with this matter is
`18 that you are providing expert consultation for
`19 Surpass, the patent owner in this case?
`20 A. Yes.
`21 Q. And have you testified as an expert
`22 witness previously?
`23 A. Yes.
`24 Q. Has your testimony ever been limited or
`25 excluded by a court?
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`1 Bohannon
`2 A. Okay.
`3 Q. You'll do that?
`4 A. Yes. See, I'm waiting for you.
`5 Q. Good. Okay. We're off to a good
`6 start.
`7 Is there any reason why you feel that
`8 you are at all impaired in being able to testify
`9 today, that is, for a health reason or other
`10 reason?
`11 A. No.
`12 Q. If I ask a question that you don't
`13 understand, please ask me to clarify the question.
`14 Will you do that?
`15 A. Oh, yeah.
`16 Q. So if you don't ask me to clarify the
`17 question, then I'm going to proceed on the
`18 assumption that you understand the question. Is
`19 that fair?
`20 A. That's fair.
`21 Q. Now, you understand that we have a rule
`22 that applies to these proceedings that says that
`23 now that we have started the deposition that you
`24 are not to confer with Mr. Helge during the course
`25 of the deposition?
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`1 Bohannon
`2 A. No.
`3 Q. Have you prepared expert reports
`4 previously?
`5 A. Yes.
`6 Q. And have any of the opinions set forth
`7 in your expert reports been limited or excluded by
`8 a court?
`9 A. No.
`10 Q. Mr. Bohannon, I have handed you a copy
`11 of what's entitled declaration of William K.
`12 Bohannon in response of Petitioner Sony
`13 Corporation, et al. Do you see that title?
`14 A. Yes. It says Sony and Samsung.
`15 Q. Correct. So do you understand the "et
`16 al." to mean Samsung?
`17 A. Yeah. So you're representing Samsung
`18 also or just Sony?
`19 Q. I represent Sony.
`20 A. Okay.
`21 Q. This has been marked and submitted in
`22 these proceedings as Exhibit 2022. Do you see
`23 that in small letters way down in the lower right
`24 corner?
`25 A. Yes, I do.
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 3
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`1 Bohannon
`2 Q. Now, do you recognize this declaration?
`3 A. Yes.
`4 Q. Is this a declaration that you
`5 prepared?
`6 A. Yes.
`7 Q. Am I correct that your signature
`8 appears on page 21?
`9 A. Yes, that's my signature.
`10 Q. And you executed this declaration on
`11 November 24th, 2015?
`12 A. Yes.
`13 MR. HELGE: Walter, let's put something
`14 on the record quickly. You mentioned that you
`15 represent Sony, but our understanding is that
`16 this deposition is intended to be the sole
`17 deposition on behalf of both Sony and the
`18 Samsung entities in this case; is that right?
`19 MR. HANLEY: That's correct.
`20 A. So you are in fact representing Samsung
`21 at this deposition, then?
`22 Q. Technically not. I'm not -- I will not
`23 say I'm representing -- I'm asking questions, and
`24 Mr. Wilson can speak on behalf of Samsung.
`25 A. Oh, he's representing Samsung?
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`1 Bohannon
`2 A. No.
`3 Q. Did you see anything that you wish to
`4 add to?
`5 A. No.
`6 Q. And am I correct in understanding the
`7 situation that this declaration sets forth all the
`8 opinions that you are offering in this matter?
`9 A. Yes.
`10 Q. Now, we're going to talk about some
`11 specific statements and matters that you've
`12 addressed here. I want to go back toward the
`13 back, actually, start back, paragraph 41. That's
`14 on page 18.
`15 A. Yeah.
`16 Q. And you say in the first sentence
`17 there: Further, I understand that the petitioners
`18 are simply looking to Nitta for the details on the
`19 AMLCD.
`20 Do you see that?
`21 A. Yes, I do.
`22 Q. Is Nitta that you refer to there
`23 identified on page 4 within paragraph 7 as one of
`24 the documents that you considered?
`25 A. Yes.
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`1 Bohannon
`2 Q. He's representing Samsung.
`3 A. Okay.
`4 And what's your name, sir?
`5 MR. WILSON: Paul Wilson.
`6 THE WITNESS: Nice to meet you. Which
`7 company are you with?
`8 MR. WILSON: Covington & Burling.
`9 THE WITNESS: Thank you.
`10 Q. Have you reviewed this declaration
`11 since you prepared it?
`12 A. Yes.
`13 Q. How recently have you reviewed it?
`14 A. I read it again a couple of days ago.
`15 Q. Apart from a couple days ago, had you
`16 reviewed it from the time you signed and up to
`17 that couple days ago?
`18 A. Probably not. Maybe a week before -- I
`19 looked at it a couple of times in the last week,
`20 let's say, so -- since I signed it in November.
`21 Q. And did you notice, in looking at this,
`22 any statements that you perceived to be erroneous?
`23 A. No.
`24 Q. Did you see anything that you wish to
`25 correct?
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`1 Bohannon
`2 Q. Is that the third bullet down on page
`3 4?
`4 A. Yeah, that looks like it.
`5 Q. And that's identified as Exhibit 1005?
`6 A. Yes. Hopefully you have those
`7 exhibits. Hopefully you have those exhibits;
`8 right?
`9 Q. I do.
`10 A. Oh, good.
`11 Q. I'm not relying on you bringing them
`12 with you.
`13 A. Good.
`14 Q. I've handed you what has been submitted
`15 in this as Exhibit 1005. You can see, just to
`16 confirm it, in the lower right corner of the first
`17 page.
`18 A. Yes.
`19 Q. Is Exhibit 1005, is this a copy of the
`20 Nitta reference that you considered?
`21 A. It looks like it.
`22 Q. Now going back to the sentence in your
`23 declaration in paragraph 41 that I read a moment
`24 ago, you said, Petitioners are simply looking to
`25 Nitta for the details on AMLCD.
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 4
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`1 Bohannon
`2 Does Nitta in fact disclose or describe
`3 an AMLCD?
`4 A. First off, my understanding, you know,
`5 based on your petition that you were looking at it
`6 for an active matrix panel.
`7 Q. And you considered the Nitta reference?
`8 A. I'm verifying that. Give me a second.
`9 So in paragraph 2 of the Nitta on page
`10 3 it says TFT active matrix -- TFT liquid crystal
`11 displays which are active matrix LCD displays. So
`12 yeah.
`13 Q. So you agree that Nitta discloses an
`14 active matrix LCD display?
`15 A. Yes.
`16 Q. Now going further down in paragraph 41
`17 to the next sentence, you say, However, they have
`18 not evaluated whether Suzuki and Nitta are
`19 compatible.
`20 Do you see that?
`21 A. I do.
`22 Q. You refer to Suzuki there. Would you
`23 look back on page 4 within paragraph 7 and tell me
`24 whether or not what you identify in 41 as Suzuki
`25 is one of the items that you considered.
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`1 Bohannon
`2 A. Same time frame.
`3 Q. Going back to the sentence, second
`4 sentence, of paragraph 41 of your declaration,
`5 again you said, They -- referring to petitioners,
`6 I gather -- have not evaluated whether Suzuki and
`7 Nitta are compatible.
`8 Do you see that?
`9 A. Yes.
`10 Q. Now, do you express an opinion here in
`11 this paragraph 41 or elsewhere in your declaration
`12 that Suzuki is not compatible with Nitta?
`13 A. I don't -- I don't think that it was --
`14 I think that it was the petitioners' job to
`15 combine Nitta and Suzuki, not mine.
`16 Q. So regardless of whether or not it's
`17 your job, I'm asking a little more simple
`18 question. Do you express the opinion that Suzuki
`19 is not compatible with Nitta either in paragraph
`20 41 or elsewhere in the declaration?
`21 MR. HELGE: Object to form.
`22 A. So paragraph 41, you know, my
`23 sentence -- the sentence that I have there, it
`24 says that they, the petitioners, haven't evaluated
`25 whether Suzuki and Nitta are compatible.
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`1 Bohannon
`2 A. Yes, sir, Exhibit 3, 1003.
`3 Q. That's the second bullet on page 4?
`4 A. Yes.
`5 Q. I've handed you a copy of United States
`6 patent application publication U.S. 2003/0156092
`7 A1. It says Suzuki, et al. Do you see down on
`8 the bottom, sir, on the first page it is
`9 identified as Exhibit 1003?
`10 A. Yes.
`11 Q. Is this a copy of the Suzuki reference
`12 that you considered?
`13 A. It appears to be.
`14 Q. Is there anything in the copy that
`15 suggests to you that it might not be?
`16 A. No.
`17 Q. Now, I've handed you now the Suzuki
`18 reference and the Nitta reference. Have you
`19 reviewed Nitta recently?
`20 A. Yeah, I looked at it around the same
`21 time that I looked at my declaration.
`22 Q. In the last couple days?
`23 A. Within the last couple days.
`24 Q. And with respect to Suzuki, same
`25 question: Have you reviewed that recently?
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`1 Bohannon
`2 Q. I see that. So my question is do you
`3 say here that they are not compatible.
`4 MR. HELGE: Object to form.
`5 A. Excuse me, what I say here is I think
`6 that the petitioners need to determine whether
`7 it's compatible or not.
`8 Q. So you're not saying here that Suzuki
`9 and Nitta are not compatible?
`10 A. My opinion is contained within that
`11 paragraph.
`12 Q. And your opinion doesn't include the
`13 expression of an opinion that Suzuki is not
`14 compatible with Nitta?
`15 A. My --
`16 MR. HELGE: Object to form again.
`17 A. Sorry. My opinion is that the
`18 petitioners needed to do a better job of combining
`19 those references.
`20 Q. We see that. So that opinion does not
`21 include the expression of an opinion that Suzuki
`22 is not compatible with Nitta; is that right?
`23 MR. HELGE: Object to form. This is
`24 asked and answered multiple times.
`25 A. I'll say it again. My opinion is
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 5
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`1 Bohannon
`2 contained within that paragraph 41, which says
`3 that you guys did not evaluate -- my opinion is
`4 you didn't evaluate whether they're compatible or
`5 not.
`6 Q. And I move to strike your answer as not
`7 responsive.
`8 Would you please listen to my question
`9 and respond to my question. My question is do you
`10 express an opinion in paragraph 41 that Suzuki is
`11 not compatible with Nitta.
`12 MR. HELGE: Object to form. Walter,
`13 his declaration says what it says.
`14 A. Nowhere in paragraph 41 does it say
`15 opinion.
`16 Q. Nowhere does it say, In my opinion, or
`17 equivalent words, Suzuki is not compatible with
`18 Nitta?
`19 MR. HELGE: Object to form.
`20 Q. Correct?
`21 A. That sentence is not in that paragraph.
`22 Q. And that thought is not in this
`23 paragraph either?
`24 MR. HELGE: Object to form.
`25 A. You're trying to get something that
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`1 Bohannon
`2 Suzuki and Nitta are compatible in this paragraph?
`3 MR. HELGE: Object to form.
`4 A. So my statement is that paragraph 41
`5 says that the petitioners didn't evaluate whether
`6 Suzuki and Nitta are compatible or not, and that
`7 would be determined whether or not what type of
`8 LCD panel is disclosed in Suzuki.
`9 And I continue to say that if this is
`10 not possible from Suzuki then the petitioners
`11 would need to evaluate whether or not Suzuki is
`12 compatible with this type of panel, the AMLCD
`13 panel. And the petition didn't include that
`14 analysis, and Mr. Credelle didn't perform that
`15 analysis either.
`16 Q. I can see all that. You're essentially
`17 paraphrasing what's in paragraph 41.
`18 A. Yes.
`19 Q. My question is directed to what's not
`20 in paragraph 41. So you understand the contents
`21 of paragraph 41, do you not, sir?
`22 A. Yes, I do.
`23 Q. Since you understand what's in
`24 paragraph 41, you can also tell me what's not in
`25 paragraph 41, could you not?
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`1 Bohannon
`2 doesn't exist.
`3 Q. So maybe we're in agreement. So an
`4 opinion that Suzuki is not compatible with Nitta
`5 doesn't exist in this paragraph; correct?
`6 A. So this paragraph says that the
`7 petitioners did not do their job properly.
`8 Q. Okay. So you don't express an opinion
`9 that Suzuki and Nitta are not compatible; correct?
`10 MR. HELGE: Object to form.
`11 A. I'm not going to -- I can't answer
`12 something that doesn't exist. My opinion is --
`13 Q. So --
`14 MR. HELGE: Please, one at a time.
`15 Q. Well, when you say it doesn't exist, do
`16 I understand you correctly that you agree with me
`17 that an opinion that Suzuki is not compatible with
`18 Nitta doesn't exist in this paragraph?
`19 MR. HELGE: Object to form.
`20 A. I'm sorry, I'm not going to agree with
`21 you. I'm not going to go beyond the four corners
`22 of my opinion, which is contained within this
`23 document, this declaration, and in paragraph 41 I
`24 don't address that issue that you're asking.
`25 Q. So you don't address whether or not
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`1 Bohannon
`2 A. There's a whole universe of stuff
`3 that's not --
`4 Q. Among the things in that universe is
`5 the absence of an opinion that Suzuki is not
`6 compatible with Nitta; correct?
`7 A. There's also that the universe outside
`8 this room is not in that paragraph either.
`9 Q. And so --
`10 A. And Mr. Credelle's opinion is not in
`11 that paragraph. If you want to make a different
`12 opinion, then you're going to have to get somebody
`13 else to write it.
`14 Q. So you've not expressed that opinion
`15 that Suzuki is not compatible with Nitta; correct?
`16 MR. HELGE: Walter, I'm going to stop
`17 this because you have asked this question
`18 about 12 times.
`19 MR. HANLEY: It's and not been
`20 answered. It's and not been answered.
`21 MR. HELGE: He has given you an answer.
`22 MR. HANLEY: I'm going to keep asking
`23 the question because I'm entitled to an
`24 answer. It's a simple question.
`25 Q. Let me ask you this: If the board were
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 6
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`1 Bohannon
`2 sitting here today -- they're going to be reading
`3 this transcript, by the way. If they were sitting
`4 here today and I asked you the question, sir, does
`5 paragraph 41 express an opinion that Suzuki is not
`6 compatible with Nitta, what would you say?
`7 A. I would say that the petitioners
`8 haven't figured -- that's not my job; it's the
`9 petitioners' job to combine those references. And
`10 the petitioner didn't do their job.
`11 Q. So it's not your job, you say, and you
`12 haven't performed that job; correct?
`13 A. No one asked me to perform that job.
`14 Q. Then I'm correct in understanding, sir,
`15 that you've not an expressed an opinion, either in
`16 paragraph 41 or elsewhere in this declaration,
`17 that Suzuki is not compatible with Nitta; is that
`18 correct?
`19 MR. HELGE: Object to form.
`20 A. My opinion is that the petitioners
`21 didn't do a good job. Whoever -- if you were in
`22 charge of writing that petition, then I would say
`23 that you failed to combine those references.
`24 Q. And your opinion does not include a
`25 statement or expression that Suzuki is not
`
`1 Bohannon
`2 MR. HELGE: Object to form, calls for
`3 speculation.
`4 A. I don't know how the board operates or
`5 not. I don't know if the board operates like you.
`6 So I really can't -- that's the same kind of
`7 speculation you're asking me to do here.
`8 Q. So if the board were interested in this
`9 question and asked you the question, you
`10 wouldn't -- you wouldn't answer the question?
`11 A. If this question was so important, why
`12 didn't you guys do a proper job with the petition?
`13 Q. I'll give you one more time, sir, and
`14 this is your chance, sir, to give a responsive
`15 answer that the board can read to this question.
`16 Okay? This is your chance.
`17 Am I correct in understanding that in
`18 paragraph 41 you've not expressed an opinion that
`19 Suzuki is not compatible with Nitta?
`20 MR. HELGE: Object to form.
`21 A. So why didn't you ask Mr. Credelle to
`22 answer this question?
`23 Q. Would you answer my question, sir?
`24 Would you answer my question, sir?
`25 A. I wasn't asked to answer that question.
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`1 Bohannon
`2 compatible with Nitta; correct?
`3 MR. HELGE: Object to form.
`4 A. My opinion was on the claims; it wasn't
`5 particularly on what you're asking. You know,
`6 it's not in there.
`7 Q. Okay.
`8 A. The declaration stands as it is, and
`9 the deposition is supposed to cover the
`10 declaration, not outside of it.
`11 Q. So the opinion that I've been referring
`12 to that Suzuki is not compatible with Nitta you
`13 say is not in the declaration; correct?
`14 MR. HELGE: Objection.
`15 A. I'm not going to say what you're
`16 saying. You want me to say what you're saying.
`17 We can do it 50 times; it's going to come out the
`18 same.
`19 Q. Sir, it's a very simple question, and
`20 you can give a simple "yes" or "no" answer to it.
`21 A. Or you can simply drop it.
`22 Q. No, I'm not going to drop it. You can
`23 give a simple "yes" or "no." If I were a member
`24 of the board and I were asking you that question,
`25 would you answer the question?
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`1 Bohannon
`2 I was asked to answer the question that I answered
`3 about the suitability of the '843 patent, and
`4 that's it.
`5 Q. And since you were not asked the
`6 question, you did not answer that question, did
`7 you?
`8 A. I was not asked to answer the question
`9 you were asking. I think you should get your own
`10 expert to answer.
`11 Q. And you didn't answer that question,
`12 did you?
`13 A. You're not asking the questions that
`14 are contained in the deposition. I mean, the
`15 deposition is supposed to set the boundaries for
`16 the questions.
`17 Q. I'm asking you about paragraph 41 in
`18 this context, sir.
`19 A. Paragraph 41 says the petitioners
`20 didn't do their job properly.
`21 Q. Yeah. And I can also ask you what it
`22 doesn't say; correct? It doesn't say that in your
`23 opinion Suzuki is incompatible with Nitta? It
`24 doesn't say that?
`25 A. It also doesn't contain the complete
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`7 (Pages 22 - 25)
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 7
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`1 Bohannon
`2 works of Shakespeare.
`3 Q. So you agree with me?
`4 MR. HELGE: Object to form. I don't
`5 know if there's a question on the table.
`6 Q. You agree with me that you don't
`7 express an opinion anywhere in this declaration
`8 that Suzuki is incompatible with Nitta?
`9 A. I'm sorry, sir, I don't have to agree
`10 with you.
`11 Q. Do you understand you're here to
`12 respond to questions that I ask you?
`13 A. I'll follow my attorney's advice on
`14 whether I should respond to this or not.
`15 Q. Do you have an understanding that
`16 Mr. Helge can advise you, instruct you, not to
`17 answer questions at this deposition?
`18 A. Excuse me?
`19 Q. Do you have an understanding that
`20 Mr. Helge can instruct you not to answer questions
`21 at this deposition?
`22 A. Yes, I understand.
`23 Q. That's your understanding? So that's
`24 the rule -- so you're not going to answer my
`25 question?
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`1 Bohannon
`2 some questions about Figures 2 and 5 of Suzuki,
`3 and that is Exhibit 1003. Do you have that?
`4 A. Yes, I do.
`5 Q. And my questions are going to be about
`6 the lower portion of Figure 2. Let's start with
`7 Figure 2. Am I correct in the lower portion of
`8 Figure 2 what's plotted is applied voltage on the
`9 Y axis, if you will, against time on the X axis?
`10 A. Yes.
`11 Q. And am I correct that the time that's
`12 represented here is the duration of two frame
`13 periods?
`14 A. Well, just on the face of Figure 2, it
`15 says time so and -- what do we have? -- A, C, E,
`16 and G. On some of this I do not see frame period.
`17 Q. Do you see above in the upper portion
`18 of the figure at the very top, do you see two
`19 double-arrowed lines and above the first one on
`20 the left it says FL1 and above the second one it
`21 says FL2?
`22 A. Yes, I see that.
`23 Q. Is FL1 one frame period and FL2 another
`24 frame period?
`25 A. I'd have to look and see if that's the
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`1 Bohannon
`2 A. I've answered your question to the best
`3 of my ability.
`4 MR. HELGE: Walter, you've got a
`5 paragraph here that says what it says.
`6 Q. We'll let the board judge on whether or
`7 not you've been responsive to that question.
`8 A. Good.
`9 Q. Now let's go on to paragraph 42. And
`10 you say in the first sentence: I believe that
`11 Suzuki is compatible with passive matrix LCD
`12 technology because Suzuki's disclosure, diagrams,
`13 and the waveforms shown in Figures 2 and 5 are
`14 compatible with passive matrix LCDs.
`15 Do you see that?
`16 A. I do.
`17 Q. So among the things you identify is
`18 Suzuki's disclosure diagrams and waveforms shown
`19 in Figures 2 and 5.
`20 So am I correct in understanding that
`21 you in your opinion Figures 2 and 5 of Suzuki,
`22 those waveforms are compatible with passive matrix
`23 LCDs? Isn't that what you say here?
`24 A. That's what I say there.
`25 Q. So what I'd like to do now is ask you
`
`1 Bohannon
`2 way the description reads.
`3 Q. Perhaps if you look at paragraph 52 --
`4 A. Yeah, I'm looking at it now.
`5 Q. -- on page 4. Okay.
`6 Do you see there about five lines down
`7 from the top of paragraph 52 it refers to frame
`8 period FL1?
`9 A. Yes.
`10 Q. And two lines after that it refers to
`11 frame period FL2?
`12 A. Yes.
`13 Q. So am I correct in understanding Figure
`14 2 that FL1 and FL2 are, respectively, a first and
`15 a second frame period?
`16 A. It's a frame period. FL1 and FL2 are
`17 frame periods.
`18 Q. Does that delineation of frame periods,
`19 FL1 and FL2, does that also apply to what's shown
`20 in the lower portion of Figure 2?
`21 A. There are dots that lead down from
`22 there, so it's a reasonable assumption.
`23 Q. What we're showing, then, in the lower
`24 portion is applied voltage for two frame periods?
`25 A. It looks like we're showing applied
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`Veritext Legal Solutions
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`8 (Pages 26 - 29)
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`SONY v. SURPASS Tech., IPR2015-00863
`Exhibit SONY-1019 Page 8
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`1 Bohannon
`2 voltage for FL1 and FL2.
`3 Q. And each of FL1 and FL2 is a frame
`4 period?
`5 A. According to paragraph 52.
`6 Q. Now, just focusing on FL1, do you see
`7 below the double arrow that's labeled FL1, there
`8 are two labels below that: SF1 and SF2?
`9 A. Yes.
`10 Q. And do you understand SF1 and SF2 are
`11 two subfields of frame period FL1?
`12 A. It looks like it, according to
`13 paragraph 53.
`14 Q. And so, as shown here, am I correct in
`15 understanding this that subfield FL1 is a duration
`16 of about half a frame period and subfield FL2 is
`17 likewise a time duration of about half a frame
`18 period?
`19 A. So you said FL2 -- is that what you're
`20 trying to say, FL2?
`21 Q. Yeah.
`22 A. It says here that FL1 is a frame
`23 period, not a half of a frame period.
`24 Q. I'm sorry, maybe I didn't say it
`25 correctly. What I'm referring to is the
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`1 Bohannon
`2 MR. HELGE: Object to form.
`3 A. It appears that -- this description of
`4 the vertical axis says it's applied voltage. I
`5 mean, as a person who has measured stuff to great
`6 detail, you can't necessarily say that's going to
`7 be the voltage that's held on the pixel. There's
`8 losses and whatnot and, you know, there's going to
`9 be an RC factor on the waveform there.
`10 So the actual voltage, that's the
`11 pixels -- or the voltage that you say is held on a
`12 pixel is probably different from this straight
`13 line. This is more just like an artist's
`14 representation of what they're applying, not
`15 what's held.
`16 Q. So it's the voltage applied to the
`17 pixel during the duration of SF1?
`18 A. The voltage they're trying to get there
`19 during SF1.
`20 Q. And the actual voltage that the pixel
`21 holds might actually differ or decay because of
`22 losses?
`23 A. It could overshoot. It could do all
`24 kinds of things. This is just the applied
`25 voltage. We're just guessing, speculating, if you
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`1 Bohannon
`2 subfields, SF1 and SF2.
`3 A. Oh.
`4 Q. Each of those is half a frame period?
`5 A. Well, we're looking at Figure 7? Oh,
`6 no, Figure 2.
`7 Q. Figure 2, yeah.
`8 A. Let me go back to Figure 2.
`9 Yeah, Figure 2. Yes, I'm now looking
`10 at Figure 2, and it appears that FL1 frame period
`11 has been divided into two pieces, SF1 and SF2.
`12 Q. So looking at the lower portion of
`13 Figure 2, during subfield SF1 am I correct in
`14 understanding that there's some voltage that's
`15 applied to a pi