Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—O1653
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS,
`
`INC., and
`
`LG ELECTRONICS U.S.A.,
`
`INC.,
`
`Petitioners,
`
`V.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY
`
`KOREA CORPORATION,
`
`Patent Owner.
`
`IPR20l5-01653
`
`Patent NO. RE43,lO6
`
`Washington, D.C.
`
`April 29, 2016
`
`CROSS-EXAMINATION OF
`
`MASUD MANSURIPUR, Ph.D.
`
`202-220-415 8
`
`%
`_
`.
`_
`Henderson Legal Services, Inc.
`www.henderson1ega1services.com
`
`HIBIT
`Qoe 3
`
`
`
`April 29, 2016
`
`IPR2015—O1653
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS,
`
`INC., and
`
`LG ELECTRONICS U.S.A.,
`
`INC.,
`
`Petitioners,
`
`V.
`
`TOSHIBA SAMSUNG STORAGE TECHNOLOGY
`
`KOREA CORPORATION,
`
`Patent Owner.
`
`IPR20l5-01653
`
`Patent NO. RE43,lO6
`
`Washington, D.C.
`
`April 29, 2016
`
`CROSS-EXAMINATION OF
`
`MASUD MANSURIPUR, Ph.D.
`
`202-220-415 8
`
`%
`_
`.
`_
`Henderson Legal Services, Inc.
`www.henderson1ega1services.com
`
`HIBIT
`Qoe 3
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`Cross—Examination of MASUD MANSURIPUR,
`
`Ph.D., a witness herein, called for examination by
`
`counsel for Patent Owner in the above—entitled
`
`matter, was taken on Friday, April 29, 2016,
`
`Commencing at 2:00 p.m. at the law offices of
`
`Rothwell, Figg, Ernst & Manbeck, P.C., 607 14th
`
`Street, NW, Washington, D.C. 20005 by Cappy
`
`Hallock, Registered Professional Reporter,
`
`Certified Realtime Reporter, Certified Livenote
`
`Reporter and Notary Public in and for the District
`
`of Columbia.
`
`202-220-415 8
`
`Henderson Legal Services, Inc.
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`BRIAN A. TOLLEFSON, ESQUIRE
`
`MICHAEL H.
`
`JONES, ESQUIRE
`
`Rothwell, Figg, Ernst & Manbeck, PC
`
`607 14th Street, N.W., Suite 800
`
`Washington, D.C. 20005
`
`202—783~604O
`
`btollefson@rfem.com
`
`mjones@rfem.oom
`
`ON BEHALF OF THE PATENT OWNER:
`
`JOSEPH A. RHOA, ESQUIRE
`
`JONATHAN A. ROBERTS, ESQUIRE
`
`Nixon & Vanderhye, PC
`
`901 North Glebe Road, 11th Floor
`
`Arlington, Virginia 22003
`
`703-816-4000 (F)
`
`703—8l6~4lOO
`
`jar@nixonvan.com
`
`jr@nixonvan.com
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`C O N T E N T S
`
`Deposition of MASUD MANSURIPUR, Ph.D.
`
`April 29, 2016
`
`EXAMINATION BY:
`
`Mr. Rhoa
`
`E X H I B I T S
`
`(attached to transcript)
`
`MANSURIPUR
`
`Exhibit 2001 Webster's Universal
`
`College Dictionary entry
`
`PREVIOUSLY MARKED EXHIBITS
`
`(exhibits retained)
`
`Exhibit 1001
`
`U.S. Patent No. RE43,106
`
`Exhibit 1002
`
`U.S. Patent NO. 5,696,750
`
`Exhibit 1012 Mansuripur Declaration for
`
`U.S. Patent No. RE43,106
`
`202-220-415 8
`
`Henderson Legal Services, Inc.
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`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPM015-01653
`
`P R O C E D I N G S
`
`WHEREUPON,
`
`MASUD MANSURIPUR, Ph.$.,
`
`A Witness called for examination, having
`
`been first duly sworn, was examined and testified
`
`as follows:
`
`BY MR. RHOA:
`
`Q
`
`A
`
`Q
`
`A
`
`CROSS-EXAMINATION
`
`Please state your name for the record.
`
`Masud Mansuripur.
`
`What is your current address?
`
`5748 North Camino del Conde,
`
`C—o—n—d—e, Tucson, Arizona 85718.
`
`MR. RHOA:
`
`I'm going to hand you
`
`Exhibit 1001, which is U.S. Re~issue Patent Number
`
`43,106. Tell me when you have it in front of you.
`
`(Previously marked Exhibit Number
`
`lOOl, first referral.)
`
`A
`
`Q
`
`I have it in front of me.
`
`Do you understand that this deposition
`
`relates to the IPR challenging this patent?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`A
`
`I understand that this deposition is
`
`regarding the IPR challenging the 'lO6 patent.
`
`Q
`
`If I refer to the ‘I06 patent today,
`
`will you understand that I'm referring to this
`
`patent which is U.S. Re—issue Patent 43,106?
`
`A
`
`Q
`
`I do understand, yes.
`
`And that is Exhibit 1001 in this
`
`proceeding, correct?
`
`A
`
`Q
`
`That's correct.
`
`You've read the 'l06 patent, right?
`
`I have read the patent.
`
`Are you familiar with it?
`
`I am familiar with the patent.
`
`MR. RHOA:
`
`I'm going to hand you
`
`Exhibit 1002 in this proceeding which is U.S.
`
`Patent Number 5,696,750.
`
`(Previously marked Exhibit Number
`
`1002, first referral.)
`
`BY MR. RHOA:
`
`Q
`
`Tell me when you have it in front of
`
`I have it in front of me.
`
`202-220-415 8
`
`Henderson Legal Services, Inc.
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`Q
`
`Exhibit 1002 is the Katayama,
`
`K—a—t—a—y-a-m—a, patent which is U.S. Patent
`
`Number 5,696,750, correct?
`
`A
`
`Q
`
`That's correct.
`
`So if I refer to Katayama today will
`
`you understand that I'm referring to U.S. Patent
`
`Number 5,696,750?
`
`A
`
`Q
`
`I do understand.
`
`You submitted a declaration in this
`
`proceeding, correct?
`
`A
`
`Q
`
`I did.
`
`And you are testifying as an expert on
`
`behalf of LG in this proceeding;
`
`is that correct?
`
`A
`
`That's what I understand,
`
`that this
`
`deposition is related to my declaration in the
`
`case of LG versus TSST.
`
`Q
`
`When was the first time you saw
`
`Katayama?
`
`A
`
`May I have a copy of my declaration,
`
`Why do you need a copy of your
`
`declaration to figure out when the first time you
`
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`saw Katayama was?
`
`A
`
`It is the date of signature.
`
`MR. RHOA: Here is a copy of your
`
`declaration which is Exhibit 1012.
`
`(Previously marked Exhibit Number
`
`1012, first referral.)
`
`A
`
`Thank you.
`
`My declaration was submitted on July
`
`30 last year, 2015, and I believe I started the
`
`Katayama patent a few months before, before that
`
`date.
`
`Have you read the entire Katayama
`
`A
`
`Q
`
`I have read the entire patent.
`
`Is this your declaration,
`
`Exhibit
`
`lOl2?
`
`A
`
`Q
`
`A
`
`Exhibit 1012 is my declaration.
`
`Did you sign that declaration?
`
`I did sign this declaration.
`
`MR. RHOA:
`
`I would like to introduce
`
`Exhibit 2001.
`
`202-220-411 5 8
`
`Henderson Legal Services, Inc.
`www.henderson1ega1servicesbom
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPRZOIS-01653
`
`(Mansuripur Deposition Exhibit No.
`
`2001 was marked for identification.)
`
`THE WITNESS:
`
`Thank you.
`
`BY MR. RHOA:
`
`Q
`
`Do you have Exhibit 2001 in front of
`
`MR.
`
`JONES:
`
`I will object to this.
`
`This is a cross—examination of his direct
`
`testimony.
`
`I don't recall him giving any direct
`
`testimony regarding this document. And to my
`
`knowledge we have never seen what this is.
`
`So I'm
`
`going to object on the scope of whatever line of
`
`questioning you're going to go with on this
`
`document. And if it goes too far we may decide
`
`it's time to stop given that this-is
`
`cross—examination.
`
`BY MR. RHOA:
`
`Q
`
`A
`
`Q
`
`Do you have Exhibit 2001 in front of
`
`I do.
`
`Exhibit 2001 is a cover and a page
`
`from Webster's Universal College Dictionary.
`
`‘ w es:-: was. »éw:~z>“v;«:::s:i
`
`.
`
`202-220-41 5 8
`
`Henderson Legal Services, Inc.
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`Please refer to the final page of Exhibit 2001.
`
`Tell me when you have that in front of you.
`
`A
`
`Q
`
`diffraction?
`
`I do.
`
`Do you see the definition of the word
`
`A
`
`Q
`
`A
`
`I do.
`
`Do you agree with that definition?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`The definition of the word diffraction
`
`in this dictionary, Exhibit 2001, reads,
`
`"The
`
`modulation of waves in response to an obstacle as
`
`an object slit or grating in the path of
`
`propagation, giving rise in light waves to a
`
`banded pattern or to a spectrum."
`
`That's a pretty general description of
`
`the process of diffraction in the electromagnetic
`
`theory, and in optics we have specific cases of
`
`diffraction that we analyze and we refer to that
`
`could be broader than the definition given here.
`
`Q
`
`This dictionary is dated 1997 and my
`
`question to you is,
`
`is that definition of
`
`diffraction reasonable to you as of 1997?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`wwwhendersonlegalserviceseom
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—01653
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`It's a reasonable definition as far as
`
`the general public's understanding of the word
`
`diffraction goes. But as I said,
`
`technically in
`
`optics and electromagnetic theory, diffraction has
`
`a specific meaning and applies to many different
`
`areas .
`
`Can you look at the Katayama patent?
`
`Sure.
`
`Again,
`
`that’s Exhibit 1002, correct?
`
`Yes.
`
`In Katayama can you please refer to
`
`A
`
`Q
`
`Column 17, around Line 13?
`
`A
`
`Q
`
`Yes.
`
`You see that paragraph that begins
`
`with "Figure 30A”?
`
`A
`
`Q
`
`Yes.
`
`Can you please review that entire
`
`paragraph which goes from Column 17, Line 12 or 13
`
`up to Line 30?
`
`A
`
`Q
`
`Sure.
`
`Tell me when you're done.
`
`,.:
`
`:;~,~y.2x~ssss;<:.«
`
`,,-,;
`
`znrxg
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.henderson1ega1serVices.c0m
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—01653
`
`A
`
`Q
`
`Okay,
`
`I have read that paragraph.
`
`That paragraph is describing an
`
`aperture limiting element 2801, correct?
`
`A
`
`Q
`
`A
`
`In reference to Figure 28.
`
`Was that an answer to the question?
`
`I completed your sentence. You said
`
`the paragraph is referring to diffraction limiting
`
`aperture 2801 in conjunction or in reference to
`
`Figure 28.
`
`Q
`
`And that paragraph is referring to two
`
`different wavelengths, a 635—nanometer wavelength
`
`and a 785—nanometer wavelength, right?
`
`A
`
`This paragraph refers to two
`
`wavelengths, 635—nanometer and 785—nanometer.
`
`Q
`
`What does the grating do to the
`
`785—nanometer wavelength?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`Here in Column 17 of Katayama, Lines
`
`22 to 25, it says the grating 3002 almost
`
`completely diffracts the 785—nanometer wavelength
`
`light nearby. And further down starting on
`
`Line 24 it says,
`
`“And the 785—nanometer wavelength
`
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`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—01653
`
`light is almost completely reflected by the
`
`aperture limiting element 2801."
`
`Q
`
`So the 785-nanometer wavelength is
`
`diffracted;
`
`is that right?
`
`A
`
`That's what it says in this paragraph.
`
`It says, “grating 3002 almost completely diffracts
`
`the 785—nanometer wavelength."
`
`Q
`
`And what does the grating do with
`
`respect to the 635—nanometer wavelength?
`
`A
`
`Same paragraph says, Line 19, starting
`
`on Line 19,
`
`"The grating 3002 completely passes
`
`the 635—nanometer wavelength light."
`
`AQ
`
`What does completely passes mean to
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`I think in this context it means that
`
`the light goes through without being diffracted.
`
`Q
`
`If you can turn to the 'lO6 patent and
`
`look at claim 7, please. Tell me when you're
`
`there.
`
`A
`
`I'm there.
`
`Claim 7 uses the term objective lens.
`
`202-220-415 8
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`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`Do you see that?
`
`Yes.
`
`Do you have an opinion on the claim
`
`A
`
`Q
`
`construction for the term objective lens?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`I have a section in my declaration,
`
`Page 30, Section 10, entitled Claim Construction.
`
`And here I have not construed the term objective
`
`lens so I give it the ordinary and common meaning
`
`of the term.
`
`Q
`
`So what is your opinion,
`
`if any,
`
`regarding the ordinary meaning of objective lens
`
`as of 1997?
`
`A
`
`Objective lens in the context of the
`
`'l06 patent refers to the lens shown, for example,
`
`in Figure 1, which is said to be prior art as the
`
`element number 17.
`
`Q
`
`Is there a difference between an
`
`objective lens and some other type of lens?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`Objective lens is a kind of lens that
`
`is just like historically in microscopy, because
`
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`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`this lens was closest to the object of
`
`observation, it was called objective lens.
`
`Q
`
`Claim 7 of the ‘lO6 patent in the
`
`first line uses the phrase beam, b-e—a—m, spots.
`
`Do you see that?
`
`Yes,
`
`I do.
`
`Do you have an opinion on the claim
`
`A
`
`Q
`
`construction for that phrase?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`I have not construed the terms of the
`
`claim language in this declaration, and so I have
`
`given them the plain ordinary meaning, beam and
`
`spot.
`
`Q
`
`Do you have any opinion on the
`
`ordinary meaning of beam spots as of 1997 as used
`
`in this patent?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`I believe that beam refers to a beam
`
`of light coming from either one of the lasers that
`
`are usually present in an optical disc drive. And
`
`when there is light beams go through the objective
`
`lens they form a bright spot and, at or near the
`
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`
`April 29, 2016
`
`IPR2015—O1653
`
`focal plane of the lens,
`
`the objective lens. My
`
`understanding of claim 7 is that beam spots refer
`
`to those spots of light.
`
`Q
`
`Claim 7 uses the phrase numerical
`
`aperture, correct?
`
`A
`
`Yes. Numerical aperture is used in
`
`Do you have an opinion on the claim
`
`construction of that phrase?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`Again,
`
`I have not construed the term
`
`numerical apertures.
`
`I have given it the ordinary
`
`meaning of the word, of the phrase.
`
`Q
`
`Do you have an opinion on the ordinary
`
`meaning of numerical aperture as of 1997?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`As used in the 'lO6 patent.
`
`Okay, so here on Page 16, Paragraph 39
`
`Q
`
`A
`
`of my declaration,
`
`in the middle of Paragraph 39 I
`
`said,
`
`"The numerical aperture may be understood as
`
`a measure of the apex angle of the cone of light
`
`formed upon passage of the laser beam through the
`
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`
`April 29, 2016
`
`IPR2015-01653
`
`objective lens.“
`
`Q
`
`Do you believe that's the ordinary
`
`meaning of that phrase as of 1997?
`
`A
`
`This is what a person of ordinary
`
`skill in the art would have understood from the
`
`term as of 1997.
`
`Q
`
`In the 'lO6 patent can you please
`
`refer to the sentence at Column 6 from Lines 60
`
`through 63?
`
`A
`
`Q
`
`A
`
`Okay.
`
`Do you see that sentence?
`
`60 to 63. Let me read it.
`
`Okay,
`
`I see the sentence between Lines
`
`60 and 63 on Column 6.
`
`Q
`
`Do you have an understanding of what
`
`the phrase "first order light" means in that
`
`sentence?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`When a light of a particular
`
`wavelength goes through a grating, diffraction
`
`grating, it could be diffracted into multiple
`
`orders. And one of those orders would be the
`
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`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—O1653
`
`first order.
`
`It could be plus first order or
`
`minus first order.
`
`Q
`
`What is the difference between plus
`
`and minus?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`If the light is originally propagating
`
`in a certain direction,
`
`then it goes through a
`
`diffraction grating. Let's suppose that the
`
`diffraction grating transmits the zero order in
`
`the same direction as the incoming beam.
`
`So the
`
`light comes in, say,
`
`from bottom to the top, and
`
`hits the diffraction grating and continues in the
`
`same direction in the zero order.
`
`Then if the
`
`grating diffracts that beam,
`
`the plus one order
`
`would be deflected to one side of the zero order
`
`and the minus one order would be diffracted to the
`
`other side of the zero order.
`
`Q
`
`So the zero order is not diffracted
`
`but
`
`the first order would be diffracted :0 some
`
`extent,
`
`the second order would be diffracted to
`
`another extent?
`
`MR.
`
`JONES: Objection.
`
`.w~---
`
`:,‘(“(M|«\‘,(;\,
`
`«s
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`202-220-415 8
`
`Henderson Legal Services, Inc.
`wwwhendersonlegalservices.c0m
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR201S-01653
`
`Is that right?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`Objection,
`
`foundation.
`
`A
`
`I have a statement to this effect in
`
`my declaration. Let me find it and read it.
`
`If you look at my declaration, Page 21
`
`and 22,
`
`the footnote there reads as follows.
`
`I
`
`say in this footnote, Footnote Number 2 starting
`
`on Page 21,
`
`"When a beam passes through a
`
`diffractive optical element, it emerges as
`
`multiple beams propagating in different albeit
`
`well~defined directions.
`
`The beam that continues
`
`to travel in the same direction as the incident
`
`beam is called the zeroth-order diffracted beam.
`
`The beams that are nearest to (in terms of their
`
`propagation direction) and on opposite sides of
`
`the zeroth order beam are the plus and minus first
`
`orders of diffraction.
`
`The next nearest beams
`
`(to
`
`the zeroth order beam) constitute the plus and
`
`minus second order beams, and so on." These
`
`various diffraction orders generally carry
`
`different amounts of optical energy, although the
`
`4559;)”; as far sssxsmzszx-*«/=;a,-'
`
`202-220-415 8
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`sum of their optical energies must equal that of
`
`the incident beam.
`
`Q
`
`In that same sentence we were talking
`
`about, Line 62, Column 6 of the 'lO6 patent?
`
`A
`
`Q
`
`Yes.
`
`What is your understanding of the
`
`diffraction efficiency of 40 percent there?
`
`Do
`
`you see that phrase?
`
`I paraphrased it, but do you
`
`see the diffraction efficiency of 40 percent
`
`there?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`Typically we talk about the percentage
`
`of optical energy that is thrown into a particular
`
`order.
`
`So the diffraction efficiency of a given
`
`order being 40 percent,
`
`that means that 40 percent
`
`of the incident optical energy is thrown into that
`
`particular order.
`
`Q
`
`A
`
`Where would the other 60 percent be?
`
`If the grating is transparent, if it
`
`doesn't absorb any of the light,
`
`the other 60
`
`percent goes into other diffractive orders, zeroth
`
`order, second order, minus fifth order. Or even
`
`202-220-4] 58
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`Henderson Legal Services, Inc.
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`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`some could be reflected from the grating.
`
`Q
`
`What is shown in Figure 6 of the 'lO6
`
`patent in your view?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`According to the 'lO6 patent, Column 6
`
`starting on Line 53, Figure 6 is a "graphical view
`
`showing zero order transmissive efficiency of the
`
`holographic ring according to the wavelengths of
`
`incident lights." Then it specifies the
`
`parameters of the system that have been used for
`
`this graph.
`
`Q
`
`So would the vertical axis be
`
`transmission efficiency?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`That is correct, and Column 6,
`
`Line 53, Figure 6,
`
`the graphical view showing zero
`
`order transmissive efficiency. And so the
`
`vertical axis would be transmission efficiency,
`
`not
`
`in percentage but in terms of fraction of the
`
`total incident power.
`
`(Reporter requests clarification.)
`
`Optical power.
`
`202-220-415 8
`
`Henderson Legal Services, Inc.
`wwwhendersonlegalservices.com
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`Q
`
`And the horizontal axis of Figure 6
`
`would be groove depth, Correct?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`Note that I'm also referring to Column
`
`to 20.
`
`In addition to Column 6?
`
`Yes.
`
`Now, could you please read the
`
`A
`
`Q
`
`A
`
`question to me?
`
`Q
`
`Is the horizontal axis of Figure 6
`
`groove depth?
`
`A
`
`Based on the description in Column 4,
`
`Lines 18 to 20, which says, "Figure 6 is a
`
`graphical View showing transmissive efficiency
`
`according to the groove depth of the holographic
`
`ring lens with regard to two wavelengths," and
`
`also based on Column 6, Line—- starting on Line 53
`
`which says, "Figure 6 is a graphical view showing
`
`zero order transmissive efficiency of the
`
`holographic ring according to the wavelengths of
`
`incident lights."
`
`I would guess that the horizontal axis
`
`7-3» Km.‘-wt»
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`1¢31(§.‘v-'1‘"LzM§<§'§,,‘,-,,E\,"
`
`202-220-415 8
`
`Henderson Legal Services, Inc.
`wwwhendersonlegalservices.com
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`shows the groove depth D in units of micron.
`
`Q
`
`Is there any diffraction being
`
`indicated in Figure 6?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`Figure 6 shows the diffraction
`
`efficiency for the zeroth order. And whenever the
`
`zeroth order efficiency drops below 100 percent,
`
`that is an indication that some diffraction is
`
`taking place,
`
`into other orders.
`
`Q
`
`So at
`
`~— Figure 6 plots two different
`
`wavelengths, right?
`
`A
`
`Figure 6 plots two different
`
`wavelengths.
`
`Q
`
`Whenever those wavelengths are at 0.5,
`
`for instance, on the vertical axis,
`
`then they are
`
`being diffracted?
`
`A
`
`Whenever the wavelengths are at 0.5?
`
`The wavelengths are not at 0.5.
`
`Q
`
`The vertical axis,
`
`the middle of the
`
`vertical axis over here is 0.5.
`
`A
`
`Yes.
`
`The middle of the vertical axis
`
`shows 0.5.
`
`202-220-415 8
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`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—01653
`
`Q
`
`Whenever the two wavelengths of
`
`Figure 6 are at that level of 0.5 are they being
`
`diffracted?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`Objection,
`
`foundation.
`
`A
`
`Q
`
`The wavelengths are not at 0.5.
`
`Okay.
`
`In Figure 6
`
`the 780—nanometer
`
`wavelength has circles on the line, correct?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`According to Column 6, Line 58 to 60,
`
`11
`
`12
`
`13
`
`14
`
`"The 780—nanometer wavelength light is transmitted
`
`via the holographic ring 353 by zero percent as
`
`shown by a solid line overlapped with a circle.“
`
`So that tells me that the solid line overlapped
`
`15 with a circle represents the wavelength
`
`16
`
`17
`
`18
`
`19
`
`20
`
`780-nanometer.
`
`Q
`
`So the line with the little circles on
`
`let me rephrase that.
`
`‘
`
`So the plot with the little circles on
`
`it in Figure 6 represents 780—nanometer
`
`21 wavelength, right?
`
`22
`
`MR.
`
`JONES: Objection,
`
`form.
`
`o
`
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`
`202-220-415 8
`
`Henderson Legal Services, Inc.
`www.hend.erson1ega1serVices.c0m
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—01653
`
`A
`
`This is a plot of diffraction
`
`efficiency for the 780—nanometer wavelength light.
`
`You are welcome.
`
`Q
`
`Do you see where the groove depth of
`
`3.4 would be in Figure 6, approximately?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`Units are not specified in Figure 6,
`
`but if I assume that the units of groove depth D
`
`are micrometer as expressed on Line 56,
`
`then I
`
`would say that the horizontal axis in Figure 6 is
`
`the groove depth in units of micrometer. And then
`
`I can see what 3.4 would be.
`
`Q
`
`At 3.4 the two plots cross,
`
`right?
`
`Around 3.4.
`
`A
`
`It plots with a circle and plus sign
`
`on the cross at several points including the point
`
`at 3.4.
`
`Q
`
`I understand you to be saying that
`
`both the 650 and 780-nanometer wavelengths would
`
`be diffracted at that point around a groove depth
`
`of 3.4;
`
`is that right?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`‘.;:zM:;
`
`i$»:s»%3E?5’c‘~'é-.r-<
`
`::;=u%szsamx;a2s=z;z;'
`
`I
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`wwwhendersonlegalserviceseorn
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`A
`
`According to the plot in Figure 6 the
`
`zero order diffraction efficiency of the grating
`
`of the holographic ring 353 would be about the
`
`same at 3.4 micron.
`
`The zero percent efficiencies
`
`would be the same.
`
`Q
`
`A
`
`And both would be diffracted?
`
`Then there would be diffraction in two
`
`different orders for the two different
`
`wavelengths.
`
`Q
`
`Both would be diffracted there,
`
`correct? Both wavelengths?
`
`MR.
`
`JONES: Objection,
`
`form.
`
`A
`
`If the diffraction efficiency of zero
`
`order is less than 100 percent, or less than 1 in
`
`this plot, and if light is not being absorbed
`
`anywhere,
`
`then there will be some diffraction for
`
`both wavelengths.
`
`MR. RHOA:
`
`No further questions at
`
`this time on cross. We reserve the right to take
`
`the deposition again if you should submit a new
`
`declaration, as with the other IPRS.
`
`MR.
`
`JONES: Chat briefly. We will be
`
`202-220-41 5 8
`
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`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`back soon.
`
`(Recess taken —— 2:55 p.m.)
`
`(After recess —— 2:59 p.m.)
`
`MR.
`
`JONES: We don't have any recross.
`
`The witness reserves the right to read and sign.
`
`(Thereupon, signature having not been
`
`waived,
`
`the examination of MASUD MANSURIPUR was
`
`concluded at 3:00 p.m.)
`
`202-220-415 8
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`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015-01653
`
`UNITED STATES OF AMERICA )
`DISTRICT OF COLUMBIA
`)
`
`the reporter before
`I, CAPPY HALLOCK,
`whom the foregoing deposition was taken, do hereby
`certify that the witness whose testimony appears
`in the foregoing deposition was sworn by me on the
`29th day o: APRIL, 2016,; commencing at 2:00 p.m ,
`and ending at 3:00 p.m.,
`Said deposition is a true record of the
`testimony given by said witness.and was thereafter
`reduced to typewritten form under my supervision and
`that the foregoing pages, 1-27, constitute a true
`and accurate record of the said witness.
`
`I further certify that present on behalf
`Of Petitioner, LG ELECTRONICS,
`INC., and LG
`ELECTRONICS U.S.A.,
`INC.,, were BRIAN A. TOLLEFSON,
`
`JONES, of Rothwell, Figg, Ernst &
`and MICHAEL H.
`Manbeck,
`PC and on behalf of Patent Owner, TOSHIBA
`SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION were
`
`JOSEPH A. RHOA, Esq. and JONATHAN A. ROBERTS of
`Nixon & Vanderhye, PC.
`I further certify that I am neither
`counsel for, related to, nor employed by any of
`the parties to the action in which this deposition
`was taken; and further that I am not a relative or
`
`employee of any attorney or counsel employed by
`the parties hereto, or financially or otherwise
`
`My Commission expires September 30, 2017
`
`Cappy Hallock, RPR, CRR, CLR
`
`:._-
`
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`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.henders0n1ega1servicescom
`
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`IPR2015—01653
`
`CERTIFICATE OF DEPONENT
`
`I hereby certify that I have read and
`
`examined the foregoing transcript, and the same is
`
`a true and accurate record of the testimony given
`
`by me.
`
`Any additions or corrections that I
`
`feel are necessary,
`
`I will attach on a separate
`
`sheet of paper to the original transcript.
`
`M «
`
`!%gé1'~{ ‘Z0 :4
`
`MASUD MANSURIPUR, Ph.D.
`
`202-220-415 8
`
`Henderson Legal Services, Inc.
`www.hendersor11ega1serViceS.com
`
`
`
`ERRATA SHEET FOR THE TRANSCRIPT OF:
`
`LG Electronics, lnc., et al. v. Toshiba Samsung Storage
`Caption:
`Technology Korea Corporation
`Deponent: Masud Mansuripur, Ph.D.
`Dep. Date: April 29, 2016
`
`I wish to make the following changes for the following reasons:
`
`Pg. Ln.
`
`Now Reads
`
`Should Read
`
`Reasons Therefore
`
`4,,
`
`4&4
`
`L':'\('z~
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`/w4~—4%7-~»5%‘°w1a«~%
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`s
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`0‘re~iv~w~—
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`T790
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`M
`
`SlGNATURE OF THE WITNESS
`
`this
`
`1:1‘ W dayof___
`
`l/\
`
`T
`
`,2o_(__é_.
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