1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`----------------------------X
`LG DISPLAY CO., LTD,
` Petitioner,
` v. Case: 1PR2015-00885
` Patent: 7,202,843
`
`SURPASS TECH INNOVATION, LLC.,
` Patent Owner.
`----------------------------X
`
` DEPOSITION OF WILLIAM BOHANNON
` New York, New York
` January 28, 2016
` 1:12 p.m.
`
`REPORTED BY:
`DANIELLE GRANT
`JOB NO. 42478
`
`LGD_000702
`
`LG Display Ex. 1014
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`----------------------------X
`LG DISPLAY CO., LTD,
` Petitioner,
` v. Case: 1PR2015-00885
` Patent: 7,202,843
`
`SURPASS TECH INNOVATION, LLC.,
` Patent Owner.
`----------------------------X
`
` DEPOSITION OF WILLIAM BOHANNON
` New York, New York
` January 28, 2016
` 1:12 p.m.
`
`REPORTED BY:
`DANIELLE GRANT
`JOB NO. 42478
`
`LGD_000702
`
`LG Display Ex. 1014
`
`
`
`2
`
` January 28, 2016
` 1:12 p.m.
`
` Deposition of WILLIAM BOHANNON, held at the
`offices of Mayer Brown, 1121 Avenue of the Americas,
`New York, New York pursuant to Notice before DANIELLE
`GRANT, a Shorthand Reporter and Notary Public of the
`State of New York.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`1 2 3 4 5 6 7 8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`LGD_000703
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`3
`
`A P P E A R A N C E S:
`Attorneys for the LG DISPLAY
` MAYER BROWN
` 1999 K Street NW
` Washington, DC 20006
` BY: WILLIAM J. BARROW, ESQ.
` wbarrow@mayerbrown.com
` ROBERT G. PLUTA, ESQ.
` (via telephone for conference with judge only)
`
`
`Attorneys for the Patent Owner
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
` 8300 Greensboro Drive
` Suite 500
` McLean, Virginia 22102
` BY: WAYNE M. HELGE, ESQ.
` whelge@dbjg.com
`
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000704
`
`
`
`4
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`WILLIAM BOHANNON, called as a witness, having been
` first duly sworn by Danielle Grant, a
` Notary Public within and for the State of
` New York, was examined and testified as
` follows:
`DIRECT EXAMINATION BY
`MR. BARROW:
` Q Mr. Bohannon, good afternoon.
`Thank you for being here today and agreeing to
`a later start time.
` Can you state your full name for
`the record?
` A William Keith Bohannon.
` Q My name is Bill Barrow. I
`represent the petitioner, LG Display in this
`proceeding. The purpose of this deposition is
`for me to ask you questions regarding the
`declaration that you submitted in connection
`with patent owner's response.
` A Yes.
` Q I understand that you were
`deposed yesterday; is that correct?
` A That's correct.
` Q That was on behalf of patent
`owner Surpass as well?
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000705
`
`
`
`5
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A Yes.
` Q That was with respect to a
`declaration in a proceeding involving Samsung
`and Sony; is that correct?
` A That's right.
` Q Is the '843 Patent also at issue
`in that proceeding?
` A It is.
` Q Prior to that, when was the last
`time you were deposed?
` A I think it was August of last
`summer.
` Q Would that have been with
`respect to Sharp's petition?
` A The '021 IPR.
` Q That involved the '843 Patent as
`well?
` A Yes, it did.
` Q Is there another patent at issue
`in that proceeding?
` A No, it's just the '843.
` Q So you're probably very familiar
`with the deposition ground rules, but I'll go
`through just a few to refresh your memory. You
`understand that you have just taken an oath
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000706
`
`
`
`6
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`that requires you to respond truthfully to the
`best of your ability to the questions I ask
`you?
` A Yes, I do.
` Q Is there any particular reason
`why you cannot give your best testimony here
`today?
` A No.
` Q Have you taken any medication
`recently or consumed any other substances that
`might impair your ability to provide truthful
`and accurate testimony today?
` A No, I have not.
` Q There is a court reporter here
`today. She's going to be taking down
`everything we say. I ask that you try to make
`sure your answers are clear and audible so that
`she can get everything down. Please try to
`refrain from nodding your head.
` A I understand.
` Q If you don't understand a
`question I ask let me know, otherwise if you
`answer I'll assume you understood the question.
` A Understood.
` Q If you need a break at any time
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000707
`
`
`
`7
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`just let me know. The only thing I ask is if
`there is a question pending you answer the
`question and then we can take a break, okay?
` A Okay.
` Q Did you do anything to prepare
`for this deposition?
` A I have relooked at the documents
`involved and I have spoken with Wayne.
` Q So said you reviewed some
`documents, I assume that would include the '843
`Patent?
` A The patent, my declaration and
`the lead patent.
` Q Did you take a look at the
`declaration of Dr. Zech?
` A Yes, I've seen that.
` Q What about his deposition
`transcript?
` A Yes, I've seen that. I can't
`recall the last time I looked at it, but I have
`read through it at least one or twice.
` Q Have you brought any documents
`with you here today?
` A I have nothing. I have my
`phone.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000708
`
`
`
`8
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q I guess that has a display, but
`we don't need to look at that.
` When were you retained,
`specifically, for this proceeding; do you
`recall?
` A I think it was last summer June
`probably 2014. Excuse me, 2015. This is 2016.
`Excuse me for getting the years wrong.
` Q I'll go ahead and hand you your
`declaration which has your CV appended to it.
`This is Patent Owner's Exhibit 2017.
` (Patent Owner's Exhibit 2017, a
` previously marked exhibit was
` referenced.)
` Q I presume you recognize this
`document.
` A Yes.
` Q Would you just please flip back
`to Appendix A, which starts at Page 21. If you
`don't mind I would like to ask you questions
`about your background and experience, it's
`quite extensive.
` On the first page, 21, you list
`your specific areas of expertise and this first
`item listed is "Drivers", would that be
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000709
`
`
`
`9
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`software drivers or driver circuits?
` A Hardware.
` Q So job circuits?
` A Just to elaborate a little.
`There are several companies I have been
`associated with have physically produced driver
`circuits, driver IC circuits. That's the
`drivers and loads, et cetera, they're talking
`about circuits, ICs.
` Q Thank you. It says right here
`from '94 to present that you have been serving
`an as independent consultant for Manx Research?
` A Yes.
` Q And I assume that's the company
`through which you do your litigation support
`work for?
` A Yes, that's Manx Research.
` Q That's the company through which
`you were obtained by counsel?
` A Yes.
` Q From 2001 to 2010 you worked for
`Planet ATE?
` A Yes.
` Q And it says here, some of your
`work related to LCD drivers?
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000710
`
`
`
`10
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A Yes.
` Q Did this work pertain to any
`particular types of LCDs?
` A So the work here is, this is a
`company that developed specialized -- as it
`states in that little writeup on Page 23 -- we
`developed specialized circuits that are used in
`tests, and I work with our customers who are
`then using our parts to test LCD driver
`circuits. And so I would visit them in their
`factories and they would show me the test
`results and how are chips worked and complained
`or didn't complain, and discussed the
`performance of various aspects of it and the
`various circuits. It was with companies that
`had a job of testing -- for producing and
`testing, speed driver circuits, all kinds.
` One of my customers was Sharp,
`for example. Our visit to Sharp LCD factories,
`and we talked to the engineers about testing
`test results and test methodologies.
` Q Could you generally describe the
`scope of your work at Computer
`Accessories/Proxima?
` A So at Computer Accessories I was
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000711
`
`
`
`11
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`their chief scientist, and my goal was to help
`them develop products. And in doing so I would
`procure a various and assorted LCD components
`and put them together, take them together, put
`them back together into products and varied --
`in a sorted -- all the products that were
`produced were associated with large-screen
`displays, not the direct view but the
`projected. So I would get direct-view LCDs
`back in the days when they weren't making large
`ones. Get the small LCDs and take them apart,
`put them together and use them in the
`projection-type environment.
` Q What sort or work did you do for
`TRW?
` A It was an aerospace company. So
`I was a program manager. I worked on various
`assorted electronic types of programs for the
`government.
` Q Did you do any work with LCD
`displays or driver circuits with TRW?
` A I worked with some display
`systems with TRW, but not necessarily LCDs,
`kind of the first LCD work I did was with
`Hughes Aircraft, who was producing an LCD
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000712
`
`
`
`12
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`projector that was used and probably still used
`in light commanding control centers, light
`crisis situations and whatnot where you have a
`large room with a large screen display system
`and you want to see airplanes moving into
`attack and that sort of thing. So we produced
`that type of projector technology back in the
`'80, early '80s.
` Q Currently, are you doing any
`other work other than your expert testimony
`work?
` A Mostly retired.
` Q I'll go ahead and hand you the
`patent at issue.
` (Exhibit 1001 was marked as LG
` Display U.S. Patent No. 7,202,843
` for identification, as of this
` date.)
` Q I handed you LG Display Exhibit
`1001 which is the '843 Patent at issue in this
`proceeding. I assume you're familiar with this
`patent?
` A Yes.
` Q If you take a look at column
`one, starting at Line 24 and I'll read this
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000713
`
`
`
`13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`into the record. "For satisfying the rapid
`switching requirements of multimedia equipment
`improving the response speed of liquid crystal
`is desired."
` I assume before you read this
`patent, actually let me back up. Prior to this
`proceeding or prior to any of the Surpass IPR
`proceedings, had you seen the '843 Patent
`before?
` A Prior to the Surpass no, I have
`not. I first saw it back in June of last year
`when I started looking at it.
` Q Okay. Prior to reviewing the
`'843 Patent, had you heard of the term,
`"response speed" in the context of LCDs?
` A Yes.
` Q And response speed refers to the
`ability of the display to refresh an image,
`correct?
` A No.
` Q How would you define response
`speed?
` A Well, if you look at an LCDs
`specification I have done a lot of work with
`specs when you procure an LCDs or you build one
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000714
`
`
`
`14
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`or modify something for some kind of customer
`requirement, the various and assorted
`parameters that are specified, one of which is
`response or response time, it's usually turn-on
`time. And generally it's specified from a
`level like fully off or 10 percent on to 90
`percent on, fully off to all on, and its rise
`time T on and a fall time T off.
` Q The levels would that be gray
`levels?
` A Likely gray levels, but more
`like -- most specifications it's described as
`the full value, so 10 percent. There's no
`particular gray level associated with that.
`It's just pure voltage to response kind of
`thing. Gray levels come after you create a
`gamma curve.
` Q Okay. So would there be a
`correlation between that percentage and the
`amount of light that passes through?
` A Yes, exactly.
` Q I mean is that, in fact, what
`that percentage value is referring to, the
`amount of light that's passing through? So in
`your example of 10 percent, would that be 10
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000715
`
`
`
`15
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`percent transmission through the pixel?
` A Yes.
` Q And then there is a direct
`correlation between the transmission and the
`voltage; is that accurate?
` A Yes. I'm sorry I didn't wait
`for you to finish.
` Q I was finished. So that's
`correct?
` A Yes.
` Q That would be a direct
`correlation, I assume?
` A Yes, that's correct. The
`manufacturers or the people developing the LCD
`will generally put out a curve called the VT
`curve, which is voltage versus transmission.
` Q So the term transmission has a
`general understanding or general meaning in the
`art?
` A Not exactly. I mean you can say
`transmittance, transmissivity or sometimes
`there's other terminologies that are used. One
`of the problems with the field is that there is
`no standard lexicon.
` Q Okay. On this issue of response
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000716
`
`
`
`16
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`speed, the '843 Patent talks about this being
`an issue, and about the need to improve the
`response speed. Prior to reviewing the '843
`Patent had you been aware of this need or
`problem?
` A Yes.
` Q Why is this a problem? Can you
`explain generally what's going on with the
`pixels?
` A It's a problem because unlike --
`so if you go back in time a little bit and
`think about the old fashioned CR keys where you
`had deflection coils and you magnetically
`control the electron beam as it painted across
`the CRG phosphorous screen and so that was
`relatively direct, whatever the input signal
`was it would go out there and point to it.
`Although CRT had a sustained function, which
`means the light glows a little bit after the
`beam has moved on. So there is a little bit of
`a response issue in CRTs versus a laser
`display -- which I've worked with -- and the
`laser display more or less just goes and
`there's no sustain at all and your eye has to
`integrate it.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000717
`
`
`
`17
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` With the LCD, the LCD molecules
`are really large, they're some of the largest
`molecules people play with. And what they do
`is they have to move under an electric field,
`so the VT curve we were talking about, so you
`apply a voltage and create an electric field
`and the LC molecules have a little bit of an
`electrical polarity involved with it and they
`move in that electric field and it takes a
`finite amount of time for them to move. And if
`you want to create a fast-moving image you need
`those molecules to keep up.
` Q One way to help them keep up is
`to apply a higher voltage?
` A Well, you kick them a little
`harder.
` Q By kicking them would that be
`applying a higher voltage?
` A Yes, there's been lots of
`schemes, but yes, that's generally its been
`applied it's -- all electronics has that kind
`of functionality, even semiconductors you're
`talking about electron transports through
`materials, and everything takes a finite amount
`of time.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000718
`
`
`
`18
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q You mentioned that there are a
`number of ways to boost the response time or
`boost the response speed, in addition to
`overdrive which the patent talks about
`extensively, are there any other ways to
`improve the response speed that you are aware
`of?
` A Well, there's many schemes that
`you can design the LCD to move faster. Like
`the cell gap controls given a particular
`material. You can have a different cell gap
`and have a smaller cell gap and the molecules
`move faster, you have a different LCD material
`with a little bit stronger polarity, the less
`viscosity. There's all kinds of parameters
`that are adjusted in the design of an LCD to
`improve the response time. There's all kinds
`of tradeoffs involved with overall image
`quality and contrast and whatnot; it's a big
`jumble.
` Q Would it be accurate to say that
`the mere application of a voltage would
`increase the response speed of a pixel?
` A Yes. It's well-known if you
`crank up the voltage and get it to move faster,
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000719
`
`
`
`19
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`people have been working with that kind of
`approach for a long time.
` Q That could be a negative or
`positive voltage?
` A Yes.
` Q The patent also talks about
`applying more than one data impulse in a single
`frame, had you heard of this concept prior to
`reading the '843 Patent?
` A Yes.
` Q That's a way to improve the
`response speed as well?
` A Yes.
` Q So both of these concepts
`overdriving and applying a polarity of impulses
`in a single frame, those were understood
`concepts in the art?
` MR. HELGE: Object to form.
` A Yes, for the most part. But
`also it's kind of the part of electronics. If
`you're building it, trying to get a driver to
`drive or some other circuit to work, you know,
`sometimes you crank it up. Everyone cranks up
`their processors to get them to go faster,
`cranking things up and hitting them harder and
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000720
`
`
`
`20
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`clocking them faster is well known.
` Q So you mentioned earlier that
`their really isn't a standard lexicon, you
`mentioned transmission, and you said there were
`other similar terms like transmittance and I
`think --
` A Transmissivity.
` Q What about the term overdriving,
`is that a standard term in the art?
` A Generally. I call it a term of
`the art in electronics because it's been around
`in just in electronics for a long time trying
`to get something over a threshold.
` Q So it's not limited to the
`application and liquid crystal displays?
` A No.
` Q So it's a standard term in
`electronics. Is it's meaning -- does it have a
`standard meaning in your opinion?
` A Well, this '843, they describe
`how all drivers use it to get a faster response
`of the LCD molecules, for example. And the
`rest of the electronics is to get the response
`or whether it's faster or if you get a response
`at all, it might kick over some hysteresis or
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000721
`
`
`
`21
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`something, that's pretty accepted.
` Q Did you ever see the term
`transmission rate before reviewing the '843
`Patent?
` A No, I have not.
` Q I believe in your declaration
`you state you had not seen that term prior to
`looking at the patent?
` A Yes, that's true.
` Q What about the term transmission
`ratio, have you ever heard of that term?
` A No, those are two fairly common
`terms. I have not heard that term transmission
`ratio like that, used together generally.
` Q Does that term have any
`particular meaning to you today?
` A It makes me think there's
`something else involved.
` Q Something else, something more
`than just transmission?
` A Ratio means in comparison to
`something else.
` Q Okay. So I think you said
`before, and correct me if I'm wrong, that
`transmission denotes the amount of light that
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000722
`
`
`
`22
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`passes through the liquid crystal?
` A Yes. I've measured it
`extensively. Generally you want to determine
`the overall efficiency of the LCD panel you're
`working with. So you have a light on this side
`that puts out X amount of however you wish to
`measure light movements or candelas and then
`you measure on the other side of the LCD panel
`and see what kind of transmissivity you've got,
`how much light is getting through.
` Q Is that how you would define
`transmissivity, how much light is getting
`through?
` A Kind of. I'm sorry for being
`indirect, but it's a little bit loose. When I
`explained it or measured it and briefed on it,
`usually you have to explain your terminology.
` Q Right. Are you familiar with
`the concept called dithering with respect to
`LCD displays?
` A Yes.
` Q Would you explain what that is?
` A Dithering, back in the early
`days of LCDs -- today you can by an LCD panel
`that produces millions of shades of color, and
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000723
`
`
`
`23
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`that comes through having a driver that's
`capable of driving many different shades of
`color. But before they had that, drivers were
`basically one bit. They were on or they were
`off. Then they started with three-bit drivers.
`So you had eight levels per color that you
`could play with when people actually wanted
`more shades of color that you can get from a
`one-bit or three-bit driver. So if you want
`between a one and a zero you turn the one on
`and off a couple of times, and then because of
`the way the molecules don't move that fast you
`turn them on and off a couple of times they'll
`appear to be in a kind of an in-between stage.
`They do the same thing with printers.
` Q In your opinion are the LCDs
`discussed in the '843 Patent limited to any
`particular types of displays, for example,
`active matrix displays or passive matrix
`displays?
` A I believe the '843 is directed
`toward an active matrix display.
` Q And passive matrix displays are
`generally known for having a slower response
`speed, would that be accurate?
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000724
`
`
`
`24
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A No.
` Q No. How would you characterize
`the difference, very generally, between active
`and passive matrix displays?
` A I'm not sure I understand the
`question.
` Q How would you explain the
`difference between active and passive matrix
`LCD display?
` A An active matrix LCD is you have
`a back plane that has an array of transistors
`that act as switches to each pixel and in a
`passive matrix LCD you have a grid of control
`lines that go to pixels. So there is no switch
`at each pixel. The difference between the
`active matrix has a switch at each pixel,
`passive matrix does not have a switch at each
`pixel.
` Q Would you please turn to Figure
`2 of the '843 Patent.
` Feel free to reference the
`corresponding disclosure. So here we have what
`appear to be two different transmission rates,
`T1 and T2, right?
` A Yes.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000725
`
`
`
`25
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q And then we have Curve C1 and
`C2, and for both of these we have a change in
`transmission rate, right?
` A Apparently.
` Q What is causing the change in
`transmission rate for C1?
` A If I refer back to Column 1
`where it describes Figure 2 around Line 53 or
`so, it says that it's a timing diagram of
`different transmission rates of a pixel. I'm
`quoting from the patent description, varied in
`accordance with the frames. Two curves C1 and
`C2 are measured when the driving circuit
`changes transmission rates from T1 to T2. The
`curve C1 shows for a pixel transmission rate of
`a pixel not overdriven, and the curve C2 shows
`a transmission rate of a pixel overdriven
`corresponding to the frames.
` I paraphrased just a little.
` Q Is a voltage being applied here
`that's causing a change in transmission rate
`for C1?
` A This curve does not show
`voltage. It shows Y axis' transmission rate,
`XX is the frame number.
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000726
`
`
`
`26
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q What's shown here is an increase
`in transmission rate, correct?
` A It shows an increase in
`transmission rate by time for C2 versus C1.
`Although they both get to the same point
`eventually.
` Q In your opinion would that
`change in transmission rate between T1 and T2,
`would that correspond to a change in voltage?
` MR. HELGE: Object to form.
` A It does not say voltage. You
`can make all kinds of assumptions, but voltage
`is not here on this curve.
` Q Can you explain to me how one
`would obtain this curve, this increase from
`transmission rate T1 to T2?
` MR. HELGE: Object to form.
` A First of all, I would have to
`ask the inventor what he means by transmission
`rate, then I could reproduce the curve.
` Q Would you characterize T2 as a
`target transmission rate based on the
`description of this figure?
` A Based on the description I don't
`see the word target. And I don't -- I can't
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000727
`
`
`
`27
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`recall that the '843 Patent uses the word
`target, maybe you've seen it.
` Q I'm not asking where it appears.
`I'm asking whether that's your opinion.
`Whether -- whether the T2 in here is a target
`value for the transmission rate based on your
`knowledge and based on your review of the
`disclosure?
` A The only thing I can say is
`since curve one and two appear in there, you
`might be able to draw that assumption.
` Q Let's flip back to Figure 1 on
`the left here on the Y axis we have pixel data
`value, and on the X axis we have -- there's
`four frames, do you see that?
` A The X axis is four frames, yes I
`see that.
` Q I'm looking at GN, which is
`right between frame M minus one and frame N, we
`have what appears to be the application of a
`particular data impulse, would you agree with
`that?
` A It looks like it. They call it
`pixel data value.
` Q That's the application of a data
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000728
`
`
`
`28
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`impulse at the beginning of frame N, right?
` A That's what it looks like. I'm
`going to check the description and see if he
`describes it similarly. He doesn't use the
`word impulse. When he describes Figure 1 he
`calls it a polarity of pixel data used for
`driving.
` Q In your opinion based on the
`disclosure and based on your review of this
`figure, is this depicting the application of a
`data impulse between the two frames or at the
`beginning of frame N?
` MR. HELGE: Object to form.
` A It might be. That seems to be
`relatively consistent with other figures.
` Q Is there any reason why it might
`not be?
` A Just because this inventor has
`developed his own lexicon, and I hate to do any
`type of assumptions.
` Q Do you understand what he means
`by pixel data value, does that have any meaning
`to you or is that a new term, like transmission
`rate?
` A No, that's consistent. If
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000729
`
`
`
`29
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`you're trying to writing out a value, you're
`writing a value of a pixel you want to achieve
`into a driver and that would then -- whether it
`was driven, written to the driver with an
`analog or digital form, it would somehow be
`converted to an analog value and then input to
`the panel, so it makes sense.
` Q Presuming for the sake of
`argument that this is depicting the application
`of data impulses between each of these frames
`at GN, GN plus 1 and so forth --
` MR. BARROW: Strike that.
` Q Would you turn to Figure 3
`please. Now this might be another term that is
`new to all of us, "blur clear converter", had
`you heard this term before reading this patent?
` A No, I had not.
` Q How do you interpret the term
`blur clear converter in Figure 3?
` A I had to read the patent
`description to see what he was talking about.
`I'm just going to find the spot where I think
`it gives a reasonable explanation of it.
` So it says here, I think it's a
`reasonable spot that helped me to understand
`
`DAVID FELDMAN WORLDWIDE, INC.
`450 Seventh Avenue - Ste 500, New York, NY 10123 1.800.642.1099
`
`LGD_000730
`
`
`
`30
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`what it meant, Column 3 about Line 24 it says,
`"Subsequently the blur clear converter 14
`continuously receives control signal C, and the
`frame data included in frame signal G and
`generates process frame signals G, including a
`plurality of overdriven data according to the
`frame data."
` Q Would you agree the blur clear
`converter performs, at least, some of the
`overdriving?
` MR. HELGE: Objec
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
