UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
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`---------------------------------X
`
`SAMSUNG ELECTRONICS CO., LTD., :
`
`SAMSUNG DISPLAY CO., LTD., :
`
`and SONY CORPORATION, :
`
` Petitioners, :
`
` v. : Case IPR2015-00863;
`
` IPR2015-00887
`
`SURPASS TECH INNOVATION LLC, :
`
` Patent Owner. :
`
`---------------------------------X
`
` DEPOSITION OF TSU-JAE KING LIU
`
` Redwood Shores, California
`
` Friday, October 30, 2015
`
` 9:00 a.m.
`
`Job No.: 95818
`
`Pages 1 - 134
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`Reported by: JENNY L. GRIFFIN, RMR, CSR, CRR, CLR
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` LICENSE NO. 3969
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`IPR2015-00887
`Exhibit 2005
`Page 1 of 203
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`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
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`---------------------------------X
`
`SAMSUNG ELECTRONICS CO., LTD., :
`
`SAMSUNG DISPLAY CO., LTD., :
`
`and SONY CORPORATION, :
`
` Petitioners, :
`
` v. : Case IPR2015-00863;
`
` IPR2015-00887
`
`SURPASS TECH INNOVATION LLC, :
`
` Patent Owner. :
`
`---------------------------------X
`
` DEPOSITION OF TSU-JAE KING LIU
`
` Redwood Shores, California
`
` Friday, October 30, 2015
`
` 9:00 a.m.
`
`Job No.: 95818
`
`Pages 1 - 134
`
`Reported by: JENNY L. GRIFFIN, RMR, CSR, CRR, CLR
`
` LICENSE NO. 3969
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`IPR2015-00887
`Exhibit 2005
`Page 1 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` Deposition of TSU-JAE KING LIU, held at:
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`2
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` Covington & Burling LLP
`
` 333 Twin Dolphin Drive, Suite 700
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` Redwood Shores, California 94065
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` 650.632.4700
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` Pursuant to notice, before Jenny L. Griffin, RMR,
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`CSR, CRR, CLR
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`PLANET DEPOS
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`IPR2015-00887
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`Page 2 of 203
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`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`3
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` A P P E A R A N C E S
`
` ON BEHALF OF PETITIONER SAMSUNG
`
` JAY I. ALEXANDER, ESQUIRE
`
` PAUL J. WILSON, ESQUIRE
`
` COVINGTON & BURLING LLP
`
` One CityCenter
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` 850 Tenth Street, NW
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` Washington, CD 2001-4956
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` 202.662.5622
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` jalexander@cov.com
`
` pwilsond@cov.com
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` ON BEHALF OF PATENT OWNER, SURPASS TECH
`
` INNOVATION LLC:
`
` WAYNE HELGE, ESQUIRE
`
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
`
` 8300 Greensboro Drive, Suite 500
`
` McLean, Virginia 22102
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` 571.765.7714
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` whelge@dbjg.com
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`PLANET DEPOS
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`Page 3 of 203
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A P P E A R A N C E S (Continued)
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`4
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` ALSO PRESENT:
`
` WILLIAM BOHANNON
`
` Manx Research
`
` 9921 Carmel Mountain Road #341
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` San Diego, California 92129
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` 619.895.7994
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` manxrsrch@aol.com
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`5
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` I N D E X
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` PAGE
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` TESTIMONY OF:
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` TSU-JAE KING LIU
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` BY MR. HELGE .......................7
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` - - -
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` INDEX OF EXHIBITS
`
` (Attached to transcript)
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` - - -
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` EXHIBITS DESCRIPTION PAGE
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` Exhibit A Dr. Liu's Handwritten 13
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` Diagram
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` Exhibit B Patent No. 4,771,278 94
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` Exhibit C Patent No. Re. 35,135, 98
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` Reissue of Patent No.
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` 4,820,956
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` Exhibit D Patent No. 4,894,645 101
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`IPR2015-00887
`Exhibit 2005
`Page 5 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`Papers and Previously Marked Exhibits
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`Referred to and not attached to the deposition:
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`6
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`Paper No. 1 Petition for Inter Partes Review 19
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`Samsung-1013 Declaration of Tsu-Jae King Liu, 38
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` PhD
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`Samsung-1010 Microelectronics Journal Paper 67
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` Published June 1998
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`Samsung-1017 Supplemental Declaration of 68
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` Tsu-Jae King Liu, PhD
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`Samsung-1007 Certified Translation of 75
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` Japanese Application
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` No. H2-214818, Filed by
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` Central Research Institute
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` of Hitachi
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`Samsung-1003 U.S. Patent Application 106
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` Publication No. US 2002/0186190
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` A1 (December 12, 2002)
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`Samsung-1004 World Intellectual Property 112
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` Organization Patent Application
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` No. WO 02/075708 A2
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`Exhibit 2005
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` P R O C E E D I N G S
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` - - -
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` TSU-JAE KING LIU,
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`being first duly sworn or affirmed to testify to the
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`truth, the whole truth, and nothing but the truth, was
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`examined and testified as follows:
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` - - -
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` THE REPORTER: Please introduce yourselves.
`
` MR. HELGE: Good morning. I am Wayne Helge
`
`from Davidson Berquist law firm for the patent owner
`
`Surpass Tech Innovation LLC. With me is William
`
`Bohannon, also working with us on this case.
`
` MR. ALEXANDER: Jay Alexander from Covington
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`and Burling on behalf of the petitioners and also the
`
`witness. And with me today is Paul Wilson, also of
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`Covington and Burling.
`
` EXAMINATION BY MR. HELGE
`
` Q. Good morning, Dr. Liu.
`
` A. Good morning.
`
` Q. I'm going to hand you a piece of paper, and
`
`this is a blank piece of paper.
`
` A. Okay.
`
` Q. Feel free to inspect both sides. Do you agree
`
`that it's blank? I'm saying this because we don't have
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`a video today.
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2005
`Page 7 of 203
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A. Sure. Yes, I agree that this piece of paper
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`that you handed me is blank on both sides.
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` Q. Thank you. And I see you don't have a pen, so
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`I'm going to give a pen.
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` Can I ask you to please draw on that piece of a
`
`paper the electrical circuit symbol for a resistor.
`
` A. The electrical circuit symbol for a resistor?
`
` Q. That's right.
`
` A. Okay.
`
` Q. And can you describe what you just drew there
`
`for me, please?
`
` A. Okay. The resistor circuit symbol that's
`
`commonly used comprises of a line that zigzags a couple
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`of times, two and a half times between two terminals.
`
` Q. Okay. Thank you.
`
` And can I ask you now to please draw a circle
`
`around your resistor symbol.
`
` A. Okay.
`
` Q. Okay. Can I ask you, in common parlance for
`
`electrical engineers, what is that symbol that's
`
`appearing on your paper right now?
`
` A. Common parlance? What do you mean?
`
` Q. Well, I would say within the field of
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`electrical engineering. Does that symbol have a
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`representation?
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A. Does that symbol have a representation? A
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`symbol is usually used to represent some circuit
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`elements.
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` Q. Okay. And what circuit element would that
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`represent?
`
` A. Well, with a circle around it, there's -- it
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`depends on context. Certainly with no circle around it,
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`that is a common symbol that designers use for
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`indicating a resistor, or it can be used to model
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`resistance in a electrical component.
`
` Q. Okay.
`
` A. So it doesn't have to physically be a resistor,
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`but some device that has resistance to current flow,
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`electrical current flow.
`
` Q. And how does the circle change that?
`
` A. Like I said, it depends on the context.
`
` Q. Okay. Let me ask you this. You've been a
`
`professor for a long time, I understand correctly?
`
` A. Yes.
`
` Q. Okay. If you were giving an exam to a student
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`who was about to graduate, and the student could either
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`pass or fail the exam, and it was a one-question exam,
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`and the question was, "Identify on this paper what this
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`circuit element is," what would that student have to say
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`to pass?
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2005
`Page 9 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`10
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` MR. ALEXANDER: Objection to the incomplete
`
`hypothetical.
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` THE WITNESS: So you're asking me to speculate
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`if I gave this symbol to a student who is about to
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`graduate in electrical engineering, for example, what
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`they would consider that symbol to be?
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`BY MR. HELGE:
`
` Q. That's right.
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` A. But if they haven't seen this symbol before?
`
`So I should speculate.
`
` Q. Well, I'm going to ask you this question. Are
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`you saying that if --
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` A. It could be like a Charlie Brown shirt or
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`something. Right? Are you asking me to -- can you be a
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`little bit more specific?
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` Q. I just want to be clear with this. I've looked
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`at your CV. It's very detailed; correct?
`
` A. Uh-huh.
`
` Q. You've had a lot of experience in electrical
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`engineering.
`
` A. Yes.
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` Q. You've done a lot of work. You're very highly
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`regarded.
`
` A. I think so.
`
` Q. And you're telling me that you're not sure what
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`IPR2015-00887
`Exhibit 2005
`Page 10 of 203
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`that symbol is; is that correct?
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` A. I didn't -- I was asking if you wanted me to
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`speculate, because this symbol is not something that we
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`would show to an electrical engineering student.
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` Q. When would somebody first encounter that symbol
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`in an electrical engineering career?
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` MR. ALEXANDER: Objection to the hypothetical.
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` THE WITNESS: I actually hadn't -- I don't
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`recall ever seeing this symbol until I reviewed one of
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`the pieces of prior art in this case.
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`BY MR. HELGE:
`
` Q. Okay. So is your testimony this morning that
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`somebody with an undergraduate degree in electrical
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`engineering would never have encountered that symbol in
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`the past? Or in their education? Is that right?
`
` A. I didn't say that. You're asking me to say if
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`somebody has never seen that symbol? I mean, I wouldn't
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`be able to guarantee that. But in the common textbook,
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`this is not a common symbol. In a typical textbook for
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`electrical engineering, this is not a common symbol that
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`is seen.
`
` Q. So you're saying that a student who is
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`graduating from university with an electrical
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`engineering degree would not be able to identify that
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`symbol; is that right?
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2005
`Page 11 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`12
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` A. They would be able to speculate; but like I
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`said, usually the circle around the symbol that's used
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`commonly to indicate a resistance, that is not -- I
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`don't recall ever seeing that before.
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` Q. If a student identified that symbol as a
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`capacitor, would that be a passing grade or a failing
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`grade?
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` MR. ALEXANDER: Objection to the incomplete
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`hypothetical.
`
` THE WITNESS: It depends on who -- like the
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`context; right? If the professor had introduced in
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`class this particular symbol with a circle around it
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`like this and had defined it to be a capacitor, then the
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`student would pass.
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`BY MR. HELGE:
`
` Q. Have you ever done that in any of your classes?
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` A. I have never drawn that symbol in my classes.
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` Q. This is the first time you've ever drawn that
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`symbol in your life?
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` A. That's true, yes.
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` Q. Have you seen any other circuit symbols that
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`use circles surrounding some other object?
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` A. Yes. So it's used for either an independent or
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`a dependent current or voltage supply. That's when you
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`see a circle.
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`IPR2015-00887
`Exhibit 2005
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` Q. So, Dr. Liu, I want to make sure I understand
`
`your testimony this morning. You would have to
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`speculate to know what that symbol means; is that right?
`
` A. If I see it in a particular context, then I
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`wouldn't need to speculate.
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` Q. Okay. But on the paper, you don't know? You
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`don't know what that symbol is?
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` A. Well, you asked me to draw the symbol, so I
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`don't know what you want me to think it is.
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` Q. It's not about my testimony, Dr. Liu, it's
`
`about your testimony. And I'm just saying, based on
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`that paper as you look at it right now, you cannot
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`identify it in that context; is that right?
`
` A. That's true. It could be a -- I don't know if
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`you want it to be a voltage supply with some resistance,
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`internal resistance. It's not clear.
`
` Q. Okay.
`
` MR. HELGE: Why don't we mark this. I'm going
`
`to ask the court reporter to please mark this as
`
`Exhibit A.
`
` (Exhibit A is marked.)
`
`BY MR. HELGE:
`
` Q. Dr. Liu, we jumped into some testimony without
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`going over some basic deposition ground rules, for
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`example.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2005
`Page 13 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A. Okay.
`
` Q. Just for the record, can you please state your
`
`14
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`full name?
`
` A. Sure. It's Tsu-Jae King Liu.
`
` Q. Okay. And you are here for Case
`
`No. IPR2015-00887; is that correct?
`
` A. Actually, I don't remember the exact number of
`
`the case.
`
` Q. Okay. You're here for a case between Samsung
`
`and Sony against Surpass Tech Innovation; correct?
`
` A. That's correct.
`
` Q. And we're talking about Patent No. 7,420,550;
`
`correct?
`
` A. The '550 patent, yes, that's correct.
`
` Q. Okay. Have you ever been deposed before,
`
`Dr. Liu?
`
` A. Yes, I have.
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` Q. Okay. And how many times have you been deposed
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`before?
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` A. I don't recall the exact number, but it is
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`probably at least four times in the past.
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` Q. Four times. Okay. And were all of those
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`depositions in the context of patent litigation?
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` A. Yes.
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` Q. And were you deposed as an expert in each of
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`IPR2015-00887
`Exhibit 2005
`Page 14 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`those cases?
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` A. Yes, I was.
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` Q. You may have been explained the ground rules
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`for depositions in those cases, so I apologize if I'm
`
`covering something that you've heard before. But I
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`think we need to just say it for the record here today.
`
` A. Sure.
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` Q. One thing is we are talking about very
`
`technical terms, and we want to speak slowly. And I
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`need to be as careful about that as anybody --
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` A. Okay.
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` Q. -- for the courtesy of the reporter so she can
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`get all that testimony and the questions into the
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`transcript.
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` A. All right.
`
` Q. Are you taking any medication that might affect
`
`your ability to give true and accurate testimony today?
`
` A. No, I am not.
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` Q. Is there any other reason why you may not be
`
`able to give true and accurate testimony today?
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` A. No.
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` Q. Another thing we need to be careful about, and
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`it seems like we're doing a pretty good job so far, is
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`not interrupting each other. The reporter can only take
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`one person's words down of the transcript at a time.
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`IPR2015-00887
`Exhibit 2005
`Page 15 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`So --
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` A. Understood.
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` Q. -- I'll be careful not to interrupt you, and
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`I'll ask you to do the same for me.
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` If I ask you a question, I'll need you to
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`answer affirmatively; a head nodding or shaking of the
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`head isn't going to make it onto the record.
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` A. I understand.
`
` Q. Thanks.
`
` Dr. Liu, there is another thing that I need to
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`read slowly for this deposition, because we're in a
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`forum called the Patent Trial and Appeal Board, and they
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`have specific rules regarding a witness's ability to
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`confer with their attorneys during a deposition. And
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`that means during breaks and it also means once I've
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`concluded my questioning of you and your attorneys may
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`have a chance to ask you some questions. And so --
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` A. Yes.
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` Q. -- the prohibition is -- I'll read it. This is
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`from the Office Patent "Trial Practice Guide."
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` "Once the cross-examination of a witness
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` has commenced, and until cross-examination of
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` the witness has concluded, counsel offering the
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` witness on direct examination shall not, A,
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` consult or confer with the witness regarding
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`IPR2015-00887
`Exhibit 2005
`Page 16 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` the substance of the witness's testimony
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` already given, or anticipated to be given
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` except for the purpose of conferring on whether
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` to assert the privilege against testifying or
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` on how to comply with the board order; or, B,
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` suggest to the witness the manner in which any
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` questions should be answered."
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` Do you understand that paragraph as I've just
`
`read it?
`
` A. I do understand it.
`
` Q. Thank you.
`
` Can I ask what you did to prepare for this
`
`deposition today?
`
` A. I met with the attorneys for Samsung and Sony
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`yesterday for about eight hours.
`
` Q. Was there anyone else present other than you
`
`and the attorneys?
`
` A. No.
`
` Q. Okay. Did you review any documents in
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`preparation for this deposition?
`
` A. I did review the documents that I relied on in
`
`my declaration.
`
` Q. Okay.
`
` A. And the declaration itself.
`
` Q. Okay. How long ago did you last read the
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`IPR2015-00887
`Exhibit 2005
`Page 17 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`18
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`declaration? How long ago did you last read the
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`declaration?
`
` A. I reviewed it -- what do you mean by review?
`
`Like in detail? Or -- I looked at it this morning, but
`
`does that count as a review?
`
` Q. Sounds like -- I think so; right? You said --
`
` A. Okay.
`
` Q. So you read it this morning?
`
` A. I glanced at it this morning.
`
` Q. Okay. When did you last read it in detail?
`
` A. Yesterday, together with the attorneys.
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` Q. Okay. As you were reading it through, did you
`
`see anything that you disagreed with or thought that you
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`would like to have corrected? Or any errors?
`
` A. No, no. Not that I can think of.
`
` Q. So there's nothing you would have changed in
`
`that declaration in preparation for this deposition?
`
` A. That's correct.
`
` Q. When did you last review the petition in this
`
`case?
`
` A. Probably in January of this year.
`
` Q. That was the last time you read the petition?
`
` A. Which petition? The original one to ask for
`
`inter partes review?
`
` Q. That's right. Of the '550 patent.
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`IPR2015-00887
`Exhibit 2005
`Page 18 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A. I think it was early this year.
`
` Q. Okay. So you did not review it in preparation
`
`for this deposition?
`
` A. I don't recall that we did that yesterday.
`
` Q. Okay. And you didn't do that on your own?
`
` A. Yesterday? No.
`
` Q. How about before yesterday?
`
` A. Earlier this year, in preparation for the --
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`writing my declaration I did.
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` Q. Did you do any preparation for this deposition
`
`before yesterday?
`
` A. No.
`
` Q. Had the petition been filed when you reviewed
`
`it, or did you review it prior to filing?
`
` A. Oh, I see. So you're talking about the
`
`petition --
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` MR. ALEXANDER: Let me just interrupt, because
`
`I'm not quite sure you understand what document he's
`
`talking about. Do you have a copy of it that you could
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`show her.
`
` MR. HELGE: Sure. We can do that.
`
`BY MR. HELGE:
`
` Q. I'll hand the witness -- this is, I believe,
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`Paper No. 1 in this case. This is the petition for
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`inter partes review.
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`IPR2015-00887
`Exhibit 2005
`Page 19 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A. Okay.
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` Q. Dr. Liu, have you seen this document before?
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` A. Okay. This document I saw for the first time
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`yesterday, when I was reviewing -- preparing for the
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`20
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`deposition today.
`
` Q. Okay.
`
` A. So -- yes. So this particular document that
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`you've just put in front of me, I only saw yesterday for
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`the first time.
`
` Q. Okay. Can you please turn to the third page of
`
`this document. This is part of the table of contents,
`
`Section 5. One more page, please. There we go.
`
` Do you see that there are -- at the bottom
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`here -- well, really the middle of the page -- seven
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`different grounds of challenge against claims of the
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`'550 patent. Do you see those seven grounds? G has 5,
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`6, and 7.
`
` A. Yes, I do see that in the table of contents.
`
` Q. Okay. And are you aware that the board has
`
`instituted on only a portion of the these claims -- or a
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`portion of these grounds?
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` A. I'm not sure exactly what the board has
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`instituted.
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` Q. Have you seen the board's institution decision
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`in this case?
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`IPR2015-00887
`Exhibit 2005
`Page 20 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`21
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` A. I did glance at that document yesterday as part
`
`of the preparation, but I didn't review it in detail.
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` Q. Okay. So you've mentioned the petition, the
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`institution decision, your declaration. Oh, I'm sorry.
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`You also mentioned the prior art references that you
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`identified in the declaration.
`
` A. Yes.
`
` Q. Were there any other documents that you
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`reviewed yesterday in preparation for the deposition?
`
` A. Not that I recall.
`
` Q. Did you read the petition in detail yesterday?
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` A. Not in great detail. Maybe because there was
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`limited time. But the outline looked consistent with
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`what was stated in my declaration.
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` Q. So you agreed with everything that you saw in
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`the petition? Everything you reviewed?
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` A. I didn't review it in sufficient detail to say
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`that I agree with everything in the petition.
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` Q. Okay. So there may be things that you disagree
`
`with that --
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` A. I don't know.
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` Q. Dr. Liu, have you ever worked at a company
`
`where you had to fill out on invention disclosure form?
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` A. Yes.
`
` Q. Which company was that?
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`Page 21 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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` A. I had to do that at Xerox Corporation when I
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`worked there, and also at Synopsys, Incorporated, when I
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`22
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`worked there.
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` Q. And at Xerox, was that referred to by the
`
`acronym PARC, P-A-R-C.
`
` A. The Palo Alto Research Center, yes.
`
` Q. Okay. Were the processes for invention
`
`disclosure forms the same at Xerox and at Synopsys?
`
` A. The forms were different and the internal
`
`review process was different.
`
` Q. Okay. Let's talk about Xerox then
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`specifically. Can you tell me generally when would you
`
`have filled out an invention disclosure form?
`
` A. After -- okay. Generally, after I conceived of
`
`a novel idea and had some evidence that it would -- that
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`it was valid.
`
` Q. Okay. And so you would fill out the invention
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`disclosure form, then, with details of that invention;
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`correct?
`
` A. Yes.
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` Q. And you would probably sign it as well; right?
`
` A. Yes.
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` Q. Okay. And then who would you give it to?
`
` A. At the company, there are some employees whose
`
`task is to receive and review and file -- you know, to
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`IPR2015-00887
`Exhibit 2005
`Page 22 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`make a record of invention disclosures.
`
` Q. So there would be some review by certain people
`
`of your invention disclosure form; is that right?
`
` A. Yes.
`
` Q. And they would review the technical details as
`
`well of what you believe is the invention?
`
` A. It depends. Ideally, every invention
`
`disclosure is reviewed, but --
`
` Q. Is it reviewed by someone with a technical
`
`background, or is it reviewed by somebody who is more
`
`administrative than just, perhaps, saying, "Yes, this
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`form is filled out completely and we'll file it away"?
`
` A. So when you say "file away," what do you mean?
`
` Q. Let me just ask the question again.
`
` Were the invention disclosure forms reviewed by
`
`someone with a technical background?
`
` A. Eventually. They should have been.
`
` Q. Okay.
`
` A. But not every invention disclosure gets turned
`
`into a patent application.
`
` Q. Sure. Based on a review; correct?
`
` A. Right. But it could be that a nontechnical --
`
`a person with nontechnical background could decide not
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`to pursue -- not to present it to a technical review
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`committee.
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`IPR2015-00887
`Exhibit 2005
`Page 23 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`24
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` Q. Okay. So if it was going to be filed as a
`
`patent application, can we presume that someone with a
`
`technical background would have reviewed that invention
`
`disclosure form before preparing the patent application?
`
` A. I think it is safe to assume that some -- at
`
`least one person with a technical background reviews
`
`each invention disclosure before it possibly is turned
`
`into a patent application.
`
` Q. Sure. And was that the way at Synopsys as
`
`well?
`
` A. Yes.
`
` Q. So based on your experience, invention
`
`disclosure forms that then result in patent applications
`
`are reviewed by someone with a technical background;
`
`correct?
`
` A. Yes.
`
` Q. I know that you've had a number of patents
`
`granted in your name. Did any of your patents result
`
`from that process at Xerox or at Synopsys?
`
` A. Yes.
`
` Q. Before the patent application was filed, but
`
`after you submitted your invention disclosure forms,
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`were you given a chance to review the patent application
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`and comment on its technical accuracy?
`
` MR. ALEXANDER: I'm just going to have a
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`IPR2015-00887
`Exhibit 2005
`Page 24 of 203
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`
`
`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`25
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`standing objection to this line of questioning as
`
`irrelevant to the proceeding. I can't stop you from
`
`asking the questions, but I want my objection noted.
`
` THE WITNESS: So the question is, did I always
`
`have a chance to review the patent application before it
`
`was filed?
`
`BY MR. HELGE:
`
` Q. Yes.
`
` A. I can't say for sure. I know certainly at the
`
`university, that's not the case. At the companies, it's
`
`been such a long time, I don't recall if I ever saw --
`
`if I always saw the final version before it was filed.
`
` Q. Did you frequently see the final version before
`
`it was filed?
`
` A. I know at least sometimes I did.
`
` Q. Because you were asked to sign a declaration
`
`that you confirmed that that's your invention; correct?
`
` A. Yes.
`
` Q. At any of your prior workplaces, did you have
`
`experience with LCD panel manufacturing?
`
` A. What do you mean by "manufacturing"? Do you
`
`mean like high-volume manufacturing, or just the
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`fabrication and testing of a functional display?
`
` Q. Let's talk about that second one that you just
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`mentioned, which is, you know, even one panel
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`IPR2015-00887
`Exhibit 2005
`Page 25 of 203
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`
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`fabrication and testing. Did you have experience with
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`26
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`that?
`
` A. Yes. At Xerox PARC.
`
` Q. Did you have experience with high-volume LCD
`
`panel manufacturing?
`
` A. Define "experience."
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` Q. Have you ever visited a manufacturing
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`facility --
`
` A. Yes, I have.
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` Q. -- that performed high-volume LCD panel
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`manufacturing?
`
` A. Yes.
`
` Q. In what capacity did you visit that
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`manufacturing facility?
`
` A. I visited a high-volume manufacturing facility
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`in Taiwan a number of years ago when I was working at
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`Xerox PARC, and afterwards as well. Because I conduct
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`research in active matrix LCD technologies. So I got to
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`see the equipment and just the logistics of how a
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`manufacturing line is operated.
`
` Q. So you visited in your capacity as a researcher
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`at Xerox; correct?
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` A. And at the university later on.
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` Q. As a professor?
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` A. Yes.
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`IPR2015-00887
`Exhibit 2005
`Page 26 of 203
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`Deposition of Tsu-Jae King Liu
`Conducted on October 30, 2015
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`27
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` Q. Okay. Would you say that the employees working
`
`at Xerox PARC in the field of active matrix LCDs were
`
`highly qualified and very intelligent people with --
`
`I'll leave it at that.
`
` Highly qualified -- let me ask this question
`
`again, because it's getting a little messy.
`
` Would you say that the employees working in the
`
`field of active matrix LCDs at Xerox were highly
`
`qualified in their field?
`
` MR. ALEXANDER: Object to the relevance.
`
` THE WITNESS: So employees -- there was a wide
`
`range of employees. So we have a receptionist,
`
`administrative staff, as well as technicians who just
`
`follow, you know, recipes.
`
` So do you mean every single employee?
`
`BY MR. HELGE:
`
` Q. I mean -- let's put it this way. The
`
`electrical engineers working at Xerox, would you say
`
`that they were highly qualified? I'll ask this again.
`
`I want to make sure I get this very clear.
`
` Would you say that the electrical engineers
`
`working in the field of active matrix LCDs at Xerox were
`
`highly qualified in their field?
`
` MR. ALEXANDER: Objection to the relevance.
`
` THE WITNESS: Again, you're just asking me to
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2005
`Page 27 of 203
`
`
`
`Deposition of Tsu-Jae King Liu
`Co
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