UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`_______________
`
`
`
`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG DISPLAY CO., LTD., and
`SONY CORPORATION,
`Petitioners,
`
`v.
`
`SURPASS TECH INNOVATION LLC,
`Patent Owner.
`
`_______________
`
`Case IPR2015-00887
`Patent 7,420,550 B2
`
`_______________
`
`
`
`PATENT OWNER SURPASS TECH INNOVATION LLC’S
`MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION OF TSU-
`JAE KING LIU
`
`
`
`
`
`
`
`
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`
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`
`
`_______________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`_______________
`
`
`
`SAMSUNG ELECTRONICS CO., LTD., SAMSUNG DISPLAY CO., LTD., and
`SONY CORPORATION,
`Petitioners,
`
`v.
`
`SURPASS TECH INNOVATION LLC,
`Patent Owner.
`
`_______________
`
`Case IPR2015-00887
`Patent 7,420,550 B2
`
`_______________
`
`
`
`PATENT OWNER SURPASS TECH INNOVATION LLC’S
`MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION OF TSU-
`JAE KING LIU
`
`
`
`
`
`
`
`
`
`
`
`
`
`Pursuant to the Scheduling Order dated September 9, 2015 (Paper 10),
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`Patent Owner Surpass timely moves for observations on cross-examination in light
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`of Patent Owner’s cross-examination of Petitioners’ witness, Dr. Tsu-Jae King Liu
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`on March 25, 2016. The transcript of Dr. Liu’s cross-examination testimony is
`
`being filed as exhibit 2027 (“Ex. 2027”). 1
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`
`
`Observations on Cross-Examination
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`1. Ex. 2027 at 141:23-142:23: Dr. Liu testified that the resistor-surrounded-
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`by-a-circle symbol she drew on Exhibit E is used in Janssen ‘708 (Ex.
`
`1004). This testimony is relevant to the technology disclosed by Janssen
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`‘708.
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`2. Ex. 2027 at 142:24-144:22: Dr. Liu testified that Figs. 1-4 and 7 of
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`Janssen ‘708 include the pixel symbol (labeled 46 and 100) that she drew
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`on Exhibit E. This testimony is relevant to the technology disclosed by
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`Janssen ‘708.
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`3. Ex. 2027 at 144:23-145:22: Dr. Liu testified that the pixel symbols 46
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`and 100 of Janssen ‘708 are described as a “pixel” only. This testimony is
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`relevant to the technology disclosed by Janssen ‘708.
`
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`1 Ex. 2027 begins on page 135 for consistency with the transcript page numbers.
`1
`
`
`
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`4. Ex. 2027 at 151:8-152:5; 157:18-20; 165:1-3: Dr. Liu testified that
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`Janssen ‘708 does not describe its technology as “liquid crystal,” and
`
`does not label any symbol as RLC or CLC. This testimony is relevant to the
`
`technology disclosed by Janssen ‘708.
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`5. Ex. 2027 at 153:14-154:3: Dr. Liu testified that she conducted a prior art
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`search after her previous deposition, but did not “specifically” search for
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`art using Janssen’s pixel symbol or the symbol of Exhibit E. This
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`testimony is relevant to the technology disclosed by Janssen ‘708 and to
`
`the probative weight of Dr. Liu’s testimony about Janssen ‘708’s pixel
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`symbol.
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`6. Ex. 2027 at 156:7-15: Dr. Liu testified that Ex. 1022, Kozaki, does not
`
`use the symbol that Dr. Liu drew on Exhibit E. This testimony is
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`relevant to the technology disclosed by Janssen ‘708 and to the probative
`
`weight of Dr. Liu’s testimony about Janssen ‘708’s pixel symbol in view
`
`of Kozaki.
`
`7. Ex. 2027 at 156:21-25: Dr. Liu testified that Ex. 1022, Kozaki discloses
`
`an ideal equivalent circuit of a liquid crystal picture element, but does not
`
`model the liquid crystal element with a resistor symbol in this ideal
`
`equivalent circuit. This testimony is relevant to the technology disclosed
`
`2
`
`
`
`
`by Janssen ‘708 and to the probative weight of Dr. Liu’s testimony about
`
`Janssen ‘708’s pixel symbol in view of Kozaki.
`
`8. Ex. 2027 at 159:21-160:4: Dr. Liu testified that Ex. 1023, Johnson, does
`
`not use the symbol that Dr. Liu drew on Exhibit E. This testimony is
`
`relevant to the technology disclosed by Janssen ‘708 and to the probative
`
`weight of Dr. Liu’s testimony about Janssen ‘708’s pixel symbol in view
`
`of Johnson.
`
`9. Ex. 2027 at 163:1-4: Dr. Liu testified that Ex. 1024, Moriyama, does not
`
`use the symbol that Dr. Liu drew on Exhibit E. This testimony is
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`relevant to the technology disclosed by Janssen ‘708 and to the probative
`
`weight of Dr. Liu’s testimony about Janssen ‘708’s pixel symbol in view
`
`of Moriyama.
`
`10. Ex. 2027 at 168:2-171:3; 173:18-20; 175:7-11: Dr. Liu testified that she
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`only reviewed two of three “References Cited” on the face of Ex. 1025
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`issued to Janssen, and she confirmed that she does not know whether the
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`third Reference Cited (Matsushita) is directed to active-matrix LCD
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`technology. This testimony is relevant to the probative weight of Dr.
`
`Liu’s testimony about the examination of Ex. 1025 and about the
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`examiner’s interpretation of Janssen’s “pixel” elements 46 and 100. See
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`Ex. 2027 at 177:11-15.
`
`3
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`
`
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`11. Ex. 2027 at 177:16-178:16: Dr. Liu confirmed her earlier testimony that
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`she had not seen Janssen’s pixel symbol 46/100 prior to reviewing
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`Janssen ‘708 for this matter, and agreed that the patent examiner who
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`examined Ex. 1025 may have been equally unfamiliar with that symbol.
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`This testimony is relevant to the probative weight of Dr. Liu’s testimony
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`about the examination of Ex. 1025 and about the examiner’s
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`interpretation of Janssen’s “pixel” elements 46 and 100.
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`12. Ex. 2027 at 179:21-180:13: Dr. Liu confirmed that a thin film transistor
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`cannot provide the required current for an incandescent lamp. This
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`testimony is relevant to whether Janssen ‘708 could be modified to use a
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`thin-film transistor to provide current to Janssen’s “pixel” elements 46
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`and 100.
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`13. Ex. 2027 at 181:16-24: Dr. Liu confirmed that there were other types of
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`transistors (i.e. transistors other than thin film transistors) in 2001 that
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`could provide sufficient current for an incandescent lamp. Dr. Liu also
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`testified that Janssen ‘708 does not describe the disclosed “transistors” as
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`“thin film transistors.” This testimony is relevant to whether Janssen
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`‘708 discloses or could be modified to use a thin-film transistor to
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`provide current to Janssen’s “pixel” elements 46 and 100.
`
`4
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`
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`14. Ex. 2027 at 182:19-25; 184:7-13: Dr. Liu testified that an understanding
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`of “ramp retrace” is necessary to understand the “function of the
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`multiplexing circuit disclosed in Janssen ‘708”, but confirmed that she
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`has not provided any further opinion on the meaning of “ramp retrace” in
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`her reply declaration. This testimony is relevant to the probative value of
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`Dr. Liu’s analysis of the technology disclosed by Janssen ‘708.
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`15. Ex. 2027 at 187:17-188:2: Dr. Liu testified that only one reference (Ex.
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`2024) in the record other than the Janssen references (Ex. 1004 and Ex.
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`1025) disclosed a symbol like Janssen’s pixel 46/100, and Ex. 2024 used
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`that symbol to model a lightbulb. This testimony is relevant to the
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`technology disclosed by Janssen ‘708.
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`Dated: April 4, 2016
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`
`
`Respectfully submitted,
`
`By: /s/ Wayne M. Helge
`Wayne M. Helge (Reg. No. 56,905)
`Donald L. Jackson (Reg. No. 41,090)
`Michael R. Casey (Reg. No. 40,294)
`Davidson Berquist Jackson & Gowdey,
`LLP
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Telephone: 571-765-7700
`Fax: 571-765-7200
`Email: whelge@dbjg.com
`Email: djackson@dbjg.com
`Email: mcasey@dbjg.com
` Counsel for Patent Owner
`
`
`
`5
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`I hereby certify that on April 4, 2016, a true and correct copy of the
`
`foregoing MOTION FOR OBSERVATIONS ON CROSS-EXAMINATION OF TSU-
`
`JAE KING LIU and Exhibit 2027 is being served via email to the Petitioners at the
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`correspondence addresses of record as follows:
`
`Lead Counsel: Jay I. Alexander (Reg. No. 32,678) of Covington & Burling LLP
`
`Backup Counsels: Andrea G. Reister (Reg. No. 36,253) and Gregory S. Discher
`(Reg. No. 42,488) of Covington & Burling LLP; Michelle Carniaux (Reg. No.
`36,098) and John Flock (Reg. No. 39,670) of Kenyon & Kenyon LLP
`
`Electronic Service: jalexander@cov.com; areister@cov.com; gdischer@cov.com,
`Sony-SurpassTech@kenyon.com
`
`
`
`JACKSON &
`
`By: /s/ Wayne M. Helge
` USPTO Reg. No. 56,905
`BERQUIST
` DAVIDSON
`GOWDEY, LLP
`8300 Greensboro Drive, Suite 500
`McLean, VA 22102
`Telephone: 571-765-7700
`Fax: 571-765-7200
`Email: whelge@dbjg.com
`
`
`
`
`
` Counsel for Patent Owner
`
`
`
`6
`
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