THOMAS CREDELLE
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`K.J. PRETECH CO., LTD., )
` Petitioner, )Case IPR2015-01866
` )(U.S. 8,215,816)
` vs. )Case IPR2015-01867
` )(U.S. 7,537,370)
`INNOVATIVE DISPLAY )Case IPR2015-01868
`TECHNOLOGIES LLC, )(U.S. 7,434,974)
` Patent Owner. )
`
` The deposition of THOMAS CREDELLE,
`called as a witness for examination, taken
`before ANDREA L. KIM, a Certified Shorthand
`Reporter of said state, CSR No. 84-3722, at, 71
`South Wacker Drive, Chicago, Illinois, on the
`2nd day of June, A.D. 2016, at 9:03 a.m.
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`THOMAS CREDELLE
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`Page 4
`1 (WHEREUPON, the witness was duly
`2 sworn.)
`3 THOMAS CREDELLE,
`4 called as a witness herein, having been first
`5 duly sworn, was examined and testified as
`6 follows:
`7 EXAMINATION
`8 BY MR. KIMBLE:
`9 Q. Do you please state your name.
`10 A. Thomas Credelle.
`11 Q. And where do you reside?
`12 A. Brentwood, California.
`13 Q. And have you been deposed
`14 before?
`15 A. Yes.
`16 Q. How many times?
`17 A. Twice.
`18 Q. Can you tell me generally the
`19 circumstances of those depositions?
`20 A. One was as a technical
`21 witness, and the second was as an IPR.
`22 Q. So let's take the first one,
`23 the technical witness.
`24 Were you an expert in that
`25 matter?
`
`Page 2
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`1 PRESENT:
`
`23
`
` MAYER BROWN LLP
`4 (71 South Wacker Drive,
`5 Chicago, Illinois 60606-4637,
`6 312-701-8641), by:
`7 MR. ROBERT G. PLUTA
`8 rpluta@mayerbrown
`9 MS. AMANDA K. STREFF
`10 astreff@mayerbrown.com
`11 appeared on behalf of the Petitioner;
`12
`13 BRAGALONE CONROY, P.C.
`14 (Chase Tower,
`15 2200 Ross Avenue, Suite 4500 W,
`16 Dallas, Texas 75201-7924
`17 214.785.6670), by:
`18 MR. JUSTIN B. KIMBLE
`19 jkimble@bcpc-law.com
`20 appeared on behalf the Patent Owner;
`21
`22
`23
`24 REPORTED BY: ANDREA L. KIM,
`25 Illinois CSR No. 84-3722.
`
`Page 3
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`Page 5
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`1 A. I was an inventor in a case, a
`2 dispute between my previous company and another
`3 company, and so I was deposed as to the details
`4 of that invention.
`5 Q. Can you recall about what year
`6 that took place?
`7 A. I probably should know. It's
`8 probably in my CV. It's so long ago.
`9 Q. Why don't I hand you a copy of
`10 your declaration and see if that will help.
`11 This has been premarked K.J. Pretech 1004 in
`12 IPR 2015-01868 regarding the '974 patent.
`13 (WHEREUPON, the document was
`14 tendered to the witness.)
`15 BY THE WITNESS:
`16 A. Let's see if I put that in
`17 here. 2008.
`18 BY MR. KIMBLE:
`19 Q. Can you point me to where you
`20 find that in your CV?
`21 A. The first line it says case
`22 Alien versus Avery, case number 08 --
`23 Q. What page is that?
`24 A. I am sorry. Page 5 of the CV.
`25 I guess it's numbered differently, the
`
`1 I N D E X
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`2 3
`
`WITNESS: PAGE:
`4 THOMAS CREDELLE
`5 EXAM by MR. KIMBLE................. 4
`6 EXAM by MR. PLUTA.................. 203
`
`7 8
`
` *****
`9 I N D E X
`10 EXHIBIT NUMBER MARKED
`11 Exhibit No. 1 Declaration of Thomas L.
`12 Credelle Case No. IPR2015-01115.............. 44
`13 Exhibit No. 2 Declaration of Thomas L.
`14 Credelle Case No. IPR2015-01114..............201
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`THOMAS CREDELLE
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`Page 8
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`1 appendix.
`2 Q. So it's the -- it was the
`3 Alien versus Avery case?
`4 A. That's right. It didn't have
`5 anything to do with intellectual ventures, but
`6 that was the deposition.
`7 Q. And you were an inventor in
`8 that case?
`9 A. Yes.
`10 Q. Not an expert, not a retained
`11 expert?
`12 A. Not a retained expert.
`13 Q. And generally what was the
`14 technology at issue there?
`15 A. RFID tag packaging.
`16 Q. Can you tell me basically what
`17 that means?
`18 A. Radio frequency ID tag is a
`19 device that was being developed by Alien
`20 Technology to replace bar codes. It's widely
`21 used in many products these days. The patent
`22 at dispute was a packaging method of how to
`23 package the antenna and the integrated circuit
`24 together.
`25 Q. And you said you were deposed
`
`1 A. I don't recall if it was
`2 anticipatory or obviousness at this point.
`3 Q. What did you do to prepare to
`4 be deposed today?
`5 A. I reread my declarations and
`6 the prior art patents and the patents at issue.
`7 Q. And when did you reread those
`8 documents?
`9 A. Over the past two weeks.
`10 Q. And do you know approximately
`11 how much time you spent rereading those
`12 documents?
`13 A. Probably a few hours, five to
`14 ten hours perhaps, and then I had a meeting
`15 with attorneys here to prepare for the
`16 deposition.
`17 Q. When did you have that
`18 meeting?
`19 A. Yesterday and the day before.
`20 Q. Approximately how long did you
`21 spend preparing for the deposition with the
`22 attorneys here?
`23 A. About 12 to 13 hours.
`24 Q. What attorneys were present
`25 during those --
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`Page 7
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`Page 9
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`1 in another instance in IPR; is that right?
`2 A. Yes, that was probably not on
`3 here. It was just two months ago. It was
`4 Surpass versus Sony.
`5 Q. And who did you work for in
`6 that case?
`7 A. Kenyon & Kenyon.
`8 Q. Were they representing the
`9 petitioner or the patent owner?
`10 A. Representing Sony, the
`11 petitioner.
`12 Q. And what technology was at
`13 issue in that case?
`14 A. LCD, LCD driving circuits.
`15 Q. And did you author a
`16 declaration in that case?
`17 A. Yes, I did.
`18 Q. In general did you render
`19 opinions that the patent at issue was not
`20 patentable in that matter in which you were
`21 deposed?
`22 A. Yes, I did.
`23 Q. And do you remember if you
`24 opined that the patent was anticipated by any
`25 prior art?
`
`1 A. Saqib Siddiqu and I met
`2 briefly with Rob. That was only a few minutes
`3 last night.
`4 Q. Did you speak with anybody
`5 else other than attorneys with Mayer Brown to
`6 prepare for the deposition?
`7 A. No.
`8 Q. If you would pull back out
`9 your report, and let's focus on the CV.
`10 A. Okay.
`11 Q. Talk to you about some of the
`12 things. Let's turn to page 4, and the entry
`13 your job with RCA Sarnoff Labs. It says you
`14 were a key contributor to novel methods of
`15 large screen flat panel TFT, right?
`16 A. Correct.
`17 Q. And that's thin film
`18 transistor?
`19 A. Yes.
`20 Q. Can you tell me generally what
`21 types of products you worked on at RCA?
`22 A. I wouldn't call them products
`23 but concepts.
`24 Q. Okay. What kind of concepts?
`25 A. We worked on a variety of flat
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`THOMAS CREDELLE
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`1 panel technologies that could be used by RCA in
`2 the future to build a hang on the wall
`3 television. We looked at flat CRTs, cathode
`4 ray tubes, that were thin but used a lot of the
`5 technology that RCA had at hand, and we looked
`6 at thin film transistor driven active matrix
`7 LCDs.
`8 We did examine plasma briefly
`9 but rejected that concept. So my own
`10 involvement with flat panel displays at RCA was
`11 to be an inventor and developer of various
`12 techniques in the flat CRT area as well as in
`13 the thin film transistor area.
`14 Q. With respect to the flat CRTs,
`15 were you ever involved in building prototypes?
`16 A. Yes, small prototypes.
`17 Q. Approximately what size?
`18 A. Five by ten inches.
`19 Q. Were those edge-lit CRTs or
`20 direct backlit CRTs?
`21 MR. PLUTA: Object to form.
`22 BY THE WITNESS:
`23 A. These devices were neither.
`24 They were a beam guided technique where
`25 electrons would be injected from the edge of a
`
`Page 11
`1 tube and be transmitted to the screen. So it
`2 could be considered an edge-lit CRT as opposed
`3 to an electron source behind the phosphorus
`4 screen.
`5 BY MR. KIMBLE:
`6 Q. You talked about TFT active
`7 matrix LCDs.
`8 What does active matrix mean?
`9 A. To me an active matrix is an
`10 array of transistors that drive the pixels.
`11 Q. Were you involved in building
`12 any prototypes of those display products?
`13 A. My research and my team's
`14 research was involved in developing the CRT
`15 technology, and we did build small on the order
`16 by two inch by two inch sized prototypes.
`17 Q. Were you -- did those products
`18 use backlighting units?
`19 A. There was no effort on
`20 backlighting. We just used light sources
`21 because these were R&D prototypes.
`22 Q. What type of light sources did
`23 you use?
`24 A. I don't recall. Whatever was
`25 available.
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`Page 12
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`1 Q. Do you recall if you used
`2 LEDs?
`3 A. We did not use LEDs.
`4 Q. During your time with RCA,
`5 were you ever involved in developing
`6 backlighting units?
`7 A. No.
`8 Q. Okay. Let's talk then about
`9 your experience after that with GE -- well,
`10 take a step back.
`11 It says in your CV that you
`12 were with RCA from 1970 to 1986; is that
`13 correct?
`14 A. That's correct.
`15 Q. From there you did go to GE;
`16 is that right?
`17 A. That's right.
`18 Q. And you were there from
`19 approximately 1986 to 1991?
`20 A. Yes.
`21 Q. So there you were a manager of
`22 TFT LCD R&D; is that right?
`23 A. Correct.
`24 Q. During your time with GE, did
`25 GE build TFT LCD products?
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`Page 13
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`1 A. Yes.
`2 Q. Did it sell TFT LCD products?
`3 A. It didn't get to the actual
`4 sales process during my tenure, but later on
`5 they sold prototypes, and then they sold the
`6 business to Thompson CSF who developed
`7 products.
`8 Q. Do you know approximately when
`9 Thompson C --
`10 A. CSF.
`11 Q. -- CSF sold products?
`12 A. I do not know when they
`13 introduced those to the market. The technology
`14 transfer to Thompson took place around 1990.
`15 Q. Do you know what types of
`16 products Thompson CSF sold?
`17 A. Avionic LCDs or LCDs for
`18 cockpits of airplanes.
`19 Q. Are those the types of
`20 products that you were working on when you were
`21 with GE?
`22 A. That was one of the types of
`23 products.
`24 Q. What other types of products?
`25 A. We were an R&D group. So our
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`THOMAS CREDELLE
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`1 efforts were aimed at that as an initial
`2 product, but in the future other applications
`3 such as monitors and TVs was in our scope.
`4 Q. During your time with GE, were
`5 you involved in building prototypes of these
`6 display products?
`7 A. Prototypes for avionics, yes.
`8 Q. Do you recall approximately
`9 the size of those prototypes?
`10 A. 5.25 inches by 5.25 inches.
`11 Q. Was there conceptual work done
`12 on larger display products?
`13 A. Not really.
`14 Q. You said that monitors and TVs
`15 were -- I don't want to put words in your
`16 mouth.
`17 A. A future product.
`18 Q. Was there thought given to the
`19 size of those products or what they would be?
`20 A. Not specifically.
`21 Q. Did the avionic prototypes
`22 utilize backlighting units?
`23 A. Yes.
`24 Q. What type of backlighting
`25 units?
`
`1 no consideration was given to LEDs.
`2 Q. Why do you say the technology
`3 didn't exist?
`4 A. The avionic display has to be
`5 a very bright display to be visible in sunlight
`6 to a pilot in an open canopy. So the amount of
`7 lumens or light output that is required by a
`8 backlight could not be achieved by any known
`9 LEDs at the time.
`10 Q. What level of brightness in
`11 terms of lumens would have been required?
`12 MR. PLUTA: Object to form.
`13 BY THE WITNESS:
`14 A. Let me put it in terms of the
`15 output brightness. The output brightness of
`16 the screen would need to be on the order of
`17 1,000 candelas per square meter.
`18 BY MR. KIMBLE:
`19 Q. Okay. Now, I want to move to
`20 the position you held after that which is -- as
`21 I understand from your CV, was with Apple
`22 Computer; is that right?
`23 A. That's correct.
`24 Q. That was from approximately
`25 1991 to 1994?
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`Page 15
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`Page 17
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`1 A. Either CCFL or hot cathode
`2 fluorescent.
`3 Q. So CCFL utilizes one or more
`4 bulbs, right?
`5 A. Correct.
`6 Q. Were these either direct
`7 back-lit or edged lit?
`8 A. They would be considered a
`9 direct backlight.
`10 Q. Do they use multiple bulbs?
`11 A. Yes.
`12 Q. For the hot cathode
`13 fluorescent products, were those direct
`14 back-lit?
`15 A. Yes.
`16 Q. And did they use multiple
`17 bulbs?
`18 A. Yes.
`19 Q. During your time with GE, did
`20 you do any work with LEDs as a light source?
`21 A. No.
`22 Q. Was there any conceptual work
`23 done or thought given to using LEDs?
`24 A. The technology didn't really
`25 exist to be practical for this application. So
`
`1 A. Yes.
`2 Q. And you were responsible for
`3 LCD engineering for the first Powerbook; is
`4 that right?
`5 A. That's correct.
`6 Q. Did Apple sell that Powerbook
`7 during your time with Apple?
`8 A. Yes.
`9 Q. And did that Powerbook utilize
`10 a backlighting unit?
`11 A. Yes.
`12 Q. Okay. Was it just one type of
`13 backlighting unit or multiple types?
`14 MR. PLUTA: Object to form.
`15 BY THE WITNESS:
`16 A. The products during the time I
`17 was at Apple used a CCFL backlight.
`18 BY MR. KIMBLE:
`19 Q. Were they direct back-lit or
`20 edge-lit?
`21 A. Edge-lit.
`22 Q. Did those edge-lit CCFL
`23 backlighting units utilize light guides?
`24 A. Yes.
`25 Q. And did they utilize one or
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`THOMAS CREDELLE
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`Page 18
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`1 more films in addition to the light guide?
`2 A. They did.
`3 Q. Do you remember the display
`4 size of those Powerbooks?
`5 A. They were typically around 10
`6 to 12 inches in diagonal.
`7 Q. Were you involved in any
`8 design work relating to LEDs as a light source?
`9 A. I was not.
`10 Q. Was there any during your time
`11 there?
`12 A. Not during my time there.
`13 Q. Do you know if that came
`14 after?
`15 A. It did.
`16 Q. Do you know when
`17 approximately?
`18 A. I think the late '90s.
`19 Q. What's the basis of your
`20 belief that that work happened in the late
`21 '90s?
`22 A. From my recollection of what
`23 was going on at the time, LEDs had become
`24 suitable and capable of the brightness required
`25 for an edge-lit LCD in that timeframe, and I
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`Page 19
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`1 believe Apple introduced products, but I
`2 couldn't tell you which year specifically they
`3 started with LEDs.
`4 Q. Do you -- so talking about
`5 when LEDs with sufficient brightness were
`6 available.
`7 Do you recall what year those
`8 were available?
`9 A. Not precisely.
`10 Q. Do you recall whether a
`11 particular company was selling them?
`12 A. Selling which?
`13 Q. The LEDs that were bright
`14 enough.
`15 MR. PLUTA: Object to form.
`16 BY THE WITNESS:
`17 A. I really don't recall the
`18 vendors. I know NICHIA is one of the main
`19 vendors of LEDs.
`20 BY MR. KIMBLE:
`21 Q. And was then too?
`22 A. And was then too, but I don't
`23 know and couldn't tell you even if I did know
`24 if Apple used that vendor.
`25 Q. Were you involved with
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`Page 20
`1 designing the CCFL backlighting units that were
`2 used at Apple during your time there?
`3 A. Yes.
`4 Q. What was your role in
`5 designing those backlighting units?
`6 A. My role -- the role of my team
`7 was to work closely with our suppliers in Japan
`8 to optimize the backlight system to meet
`9 Apple's requirements for brightness and
`10 uniformity.
`11 Q. So were the backlighting units
`12 designed by the vendors or by Apple?
`13 A. It was a cooperative effort.
`14 Q. Do you recall who the vendors
`15 were?
`16 A. I couldn't tell you.
`17 Q. What do you mean by that?
`18 A. I know who the vendors were,
`19 but Apple's policy, and I respect it, is not to
`20 disclose vendors of products.
`21 Q. Okay. I want to skip ahead.
`22 If you look at the second page of your CV to
`23 your time with Clairvoyante?
`24 A. Yes.
`25 Q. This was in 2001 to 2007.
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`Page 21
`1 What type of company was Clairvoyante?
`2 A. Clairvoyante was a startup
`3 company that was developing novel pixel
`4 arrangements and algorithms to drive the data
`5 to those pixels in order to reduce the power
`6 and improve the brightness of an LCD.
`7 Q. Were you involved in starting
`8 up Clairvoyante?
`9 A. I was an early employee, but I
`10 was not a founder.
`11 Q. And did Clairvoyante make
`12 product?
`13 A. No.
`14 Q. The first bullet point there
`15 says: "Responsible for engineering, product
`16 development, product roadmap, marketing of
`17 technology."
`18 Is that technology referred to
`19 there what you just described?
`20 A. Yes, the pixel architectures
`21 and the algorithms.
`22 Q. In the fourth bullet point
`23 down you talk about monthly interaction with
`24 leading LCD producers?
`25 A. Correct.
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`THOMAS CREDELLE
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`1 Q. When you say LCD, do you
`2 mean -- and I am not trying to put words in
`3 your mouth -- does that refer to liquid crystal
`4 display module?
`5 A. Yes.
`6 Q. That's the panel with the LC
`7 and the backlighting unit?
`8 A. That's correct.
`9 Q. Who were at that time the
`10 leading LCD producers?
`11 A. We met with a dozen or more
`12 vendors in Japan, for example, Toshiba, Sharp,
`13 Matshusita in Korea, Samsung, LG in Taiwan, Chi
`14 Mei, AUO, CPT, and others.
`15 Q. Were you involved during your
`16 time with Clairvoyante in designing or
`17 developing backlighting units?
`18 A. No.
`19 Q. In terms of your professional
`20 background, not your expert witness background,
`21 have you been involved in any design or
`22 development of backlighting units other than
`23 what we have talked about so far?
`24 A. One other collaborative effort
`25 I have had over the last maybe five years off
`
`1 BY THE WITNESS:
`2 A. Okay. I will make it public.
`3 Outdoor applications such as vehicle displays
`4 or digital signage.
`5 BY MR. KIMBLE:
`6 Q. If you would turn with me to
`7 page 7 of your CV.
`8 A. Okay.
`9 Q. I want to ask you first about
`10 the consulting engagement listed for Display
`11 Engineering, Inc.
`12 A. Yes.
`13 Q. And that's from March 2008 to
`14 the present?
`15 A. Right.
`16 Q. Is that still to the present
`17 today?
`18 A. Not so intense, only
`19 occasional, but that is the same company as
`20 Gemlight.
`21 Q. And did you say some of your
`22 work there related to replacing CCFLs as a
`23 light source with LEDs?
`24 A. That's correct.
`25 Q. And did it go the other way
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`Page 23
`1 and on is to work with a company in San Jose
`2 that develops high brightness LCDs by
`3 replacing, for example, CCFL lamps with LED
`4 strips or by replacing low brightness LEDs with
`5 high brightness LEDs.
`6 So I have some direct
`7 connection with the backlights in that sense,
`8 but I am not an employee of the company. I am
`9 just a consultant.
`10 Q. What company are you a
`11 consultant to?
`12 A. It's called Gemlight
`13 Technologies.
`14 Q. G-E-M?
`15 A. Yes.
`16 Q. And do you do this under TLC
`17 Display Consulting?
`18 A. Yes.
`19 Q. And if I missed, I apologize.
`20 What types of products are those backlighting
`21 units used in?
`22 MR. PLUTA: I just want to caution
`23 you. I don't know what kind of arrangements
`24 you have confidentiality wise, but this is all
`25 public.
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`Page 25
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`1 replacing LEDs with CCFLs?
`2 A. No.
`3 Q. And why is that?
`4 A. Mostly for reasons of power
`5 consumption and brightness.
`6 Q. LEDs consume less power; is
`7 that correct?
`8 A. They consume less power and
`9 these days they are brighter.
`10 Q. When you say "these days they
`11 are brighter," when did that become the case?
`12 A. I don't recall --
`13 MR. PLUTA: Object to form.
`14 BY THE WITNESS:
`15 A. -- the exact time.
`16 BY MR. KIMBLE:
`17 Q. Do you have an idea of when
`18 that happened?
`19 MR. PLUTA: Object to form, calls
`20 for speculation.
`21 BY THE WITNESS:
`22 A. I really couldn't put a date
`23 on it, but if you look at the industry
`24 adoption, LEDs are being used in almost all
`25 products these days, and that's because they
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`THOMAS CREDELLE
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`1 are brighter and now cost effective.
`2 BY MR. KIMBLE:
`3 Q. Was any of the -- strike that.
`4 Were any of the backlighting
`5 units that you have been working on for Display
`6 Engineering, Gemlight going to televisions or
`7 monitors or laptops?
`8 MR. PLUTA: Object to form.
`9 BY THE WITNESS:
`10 A. Can you -- so what are you
`11 asking the products that were used?
`12 BY MR. KIMBLE:
`13 Q. Uh-huh.
`14 A. As I mentioned already, they
`15 were used in outdoor applications such as
`16 vehicle displays and digital signage.
`17 Q. Understood.
`18 And I guess my question just
`19 to be clear is whether they were used in other
`20 products besides those such as TVs?
`21 A. Not to my knowledge.
`22 Q. All right. On page 7 you also
`23 list a consulting arrangement with LG Display?
`24 A. Correct.
`25 Q. For August 2009 to December
`
`1 BY THE WITNESS:
`2 A. That's confidential.
`3 BY MR. KIMBLE:
`4 Q. So you do know?
`5 A. I know how much I was paid. I
`6 choose not to disclose that.
`7 MR. PLUTA: I will object to the
`8 relevance of the question too.
`9 BY MR. KIMBLE:
`10 Q. So you said you traveled to
`11 LGD's offices multiple times?
`12 A. Yes.
`13 Q. When else have you been to
`14 LGD's offices?
`15 MR. PLUTA: Objection.
`16 BY THE WITNESS:
`17 A. I would say mostly during the
`18 Clairvoyante time.
`19 BY MR. KIMBLE:
`20 Q. Do you know how many times you
`21 traveled there during the Clairvoyante time?
`22 A. Not precisely but probably
`23 more than ten times.
`24 Q. During those visits, did you
`25 talk to anybody at LG Display about the
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`1 2011; is that right?
`2 A. Uh-huh.
`3 Q. Did this relate to litigation?
`4 A. No.
`5 Q. And with whom at LG Display
`6 did you work?
`7 A. I worked with the OLED team,
`8 but I don't recall the individual's name at
`9 this point.
`10 Q. During your work for LG
`11 Display, did you have occasion to go to LGD's
`12 offices in Korea?
`13 A. Yes.
`14 Q. How many times?
`15 A. I have been to LG Display
`16 offices many times under different capacities,
`17 but for this project, probably twice.
`18 Q. Under this particular
`19 consulting arrangement, did you do any work on
`20 anything other than OLED displays?
`21 A. No.
`22 Q. Do you know approximately how
`23 much money you were paid by LG Display for this
`24 consulting arrangement?
`25 MR. PLUTA: Object to form.
`
`1 backlighting units?
`2 A. No.
`3 Q. Have you done any other
`4 consulting with LG Display since December of
`5 2011?
`6 A. No.
`7 Q. All right. Look at page 5 of
`8 your CV, please.
`9 You have an entry for November
`10 2011 for an expert engagement with Steptoe and
`11 Johnson.
`12 Do you see that?
`13 A. Yes, I do.
`14 Q. Do you recall who you spoke
`15 with at Steptoe?
`16 A. I don't recall.
`17 Q. Do you recall what office they
`18 were in?
`19 A. It was a short engagement, and
`20 I would have to look up in my records.
`21 Q. Generally what were you
`22 engaged to do?
`23 MR. PLUTA: Object to form,
`24 relevance.
`25
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`1 BY THE WITNESS:
`2 A. I was engaged to be an expert
`3 or I was considered for an expert report.
`4 BY MR. KIMBLE:
`5 Q. And you say here it had to do
`6 with the ITC case?
`7 A. That's right.
`8 Q. Do you know who was the party
`9 that you would have been working for?
`10 A. The client?
`11 Q. Uh-huh.
`12 A. I frankly don't recall. It
`13 was a long time ago.
`14 Q. Do you recall what the
`15 technology was?
`16 A. I would have to look at my
`17 records.
`18 Q. Do you know if it had anything
`19 to do with LCD technology?
`20 A. With that particular case, I
`21 don't recall. I imagine it did, but I don't
`22 recall precisely since. That is my field of
`23 expertise.
`24 Q. Do you recall if it had
`25 anything to do with backlighting units?
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`1 Gibson and Dunn's client?
`2 A. I believe it was Sharp.
`3 Q. And do you recall if Sharp was
`4 the plaintiff or the defendant?
`5 A. I believe they were the
`6 defendant.
`7 Q. Do you remember if you were
`8 engaged to opine about validity in that case?
`9 A. I was hired to write a report
`10 which included that, but I never did it.
`11 Q. Would it also have included
`12 infringement or was it just validity?
`13 A. I don't recall.
`14 Q. Do you remember who you worked
`15 with at Gibson and Dunn?
`16 A. I don't recall his name.
`17 Q. Do you remember what office he
`18 was out of?
`19 A. I think he was out of Palo
`20 Alto.
`21 Q. All right. Do you recall what
`22 parts of the LCD backlighting units you were
`23 focused on in that case?
`24 MR. PLUTA: Object to form.
`25
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`1 A. I am fairly certain it did
`2 not.
`3 Q. Do you know whether the client
`4 was LG Display?
`5 MR. PLUTA: Object to form.
`6 BY THE WITNESS:
`7 A. I don't recall.
`8 BY MR. KIMBLE:
`9 Q. All right. There's another
`10 entry that is two entries down. It says the
`11 type of matter was LCD backlighting?
`12 A. Right.
`13 Q. And the client was Gibson and
`14 Dunn?
`15 A. Yes.
`16 Q. And this was -- the time of
`17 the engagement was two months, June and July
`18 2012?
`19 A. Yes.
`20 Q. Did you author a report in
`21 that case?
`22 A. No, I was retained to write a
`23 report, but the case settled before I got
`24 involved.
`25 Q. And do you recall who was
`
`1 BY THE WITNESS:
`2 A. It was such a brief engagement
`3 I don't recall. I know it had something to do
`4 with LEDs if that was your question, but I
`5 don't recall the details.
`6 BY MR. KIMBLE:
`7 Q. Do you recall if it was
`8 edge-lit backlighting units?
`9 A. I don't recall.
`10 Q. Do you remember what the
`11 alleged infringing products were in that case?
`12 A. I do not.
`13 Q. Okay. So I want to skip two
`14 engagements down -- no, that's not right,
`15 sorry. I want you to look at page 6, and
`16 there's another engagement relating to LCD
`17 backlighting.
`18 Do you see that?
`19 A. Uh-huh.
`20 Q. And this is for Shearman &
`21 Sterling?
`22 A. Yes.
`23 Q. And it says you were engaged
`24 from March 2015 through July 2015; is that
`25 right?
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`1 A. Yes.
`2 Q. Do you know who you worked
`3 with at Shearman & Sterling?
`4 A. I don't recall. I just don't
`5 remember the names. If I knew you were going
`6 to ask such questions, I would have refreshed
`7 my memory on all these past cases, but I don't
`8 tend to remember them after the case is done.
`9 Q. It's not a problem.
`10 Who was Shearman & Sterling's
`11 client?
`12 A. I don't recall.
`13 Q. Do you know if it was
`14 Mercedes?
`15 A. Was that Mercedes? Yeah, that
`16 probably is the Mercedes case. They changed
`17 names to Fried Frank; is that correct?
`18 Q. I think that is right.
`19 A. Then that would be the
`20 Mercedes case.
`21 Q. Did you ever duri