throbber
D. Cairns
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` ____________________________
` Samsung Electronics Co., Ltd.
` Petitioner
` v.
` UUSI, LLC d/b/a Nartron
` Patent Owner
` _____________________________
` Case No. IPR2016-00908
` Patent No. 5,796,183
` _____________________________
`
` DEPOSITION OF DARRAN R. CAIRNS
` Washington, D.C.
` April 21, 2017
`
`Reported by: Mary Ann Payonk
`Job No. 122665
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`SAMSUNG ET AL. EXHIBIT 1018
`Samsung v. Nartron
`IPR2016-00908
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` D. Cairns
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` April 21, 2017
` 9:30 a.m.
`
` Deposition of DARRAN R. CAIRNS, held at
`the law offices of Paul Hastings, 875 15th
`Street, N.W., Washington, D.C., pursuant to
`Notice before Mary Ann Payonk, Nationally
`Certified Realtime Reporter and Notary Public
`of the District of Columbia, Commonwealth of
`Virginia, and State of New York.
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` D. Cairns
`APPEARANCES:
`PAUL HASTINGS
`Attorneys for Petitioner
`875 15th Street, NW
`Washington, DC 20005
`BY: CHETAN BANSAL, ESQ.
` JOSEPH PALYS, ESQ.
`
`DiMURO GINSBERG
`Attorneys for Patent Owner
`1101 King Street
`Alexandria, VA 22314
`BY: TERESA SUMMERS, ESQ.
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` D. Cairns
`DARRAN R. CAIRNS,
` called as a witness, having been duly
` sworn, was examined and testified as
` follows:
` EXAMINATION
`BY MR. BANSAL:
` Q. Good morning, Dr. Cairns. Could you
`please state your name and spell it for the
`record?
` A. It's Darran, that's D-A-R-R-A-N, and
`then my middle name is Robert. That's
`R-O-B-E-R-T. And my last name is Cairns.
`That's C-A-I-R-N-S.
` Q. Dr. Cairns, have you been deposed
`before?
` A. Yes.
` Q. How many times?
` A. I don't recall exactly. Somewhere
`between four and six, I think.
` Q. What was the subject matter of each
`of those depositions?
` A. I have been deposed on touchscreen
`technology. I have been deposed on flexible
`credit cards with embedded electronics. I've
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`been deposed on polishing cloths, polishing
`material for manufacture of semiconductors.
` Q. So the case that you mentioned about
`touchscreen technology, what was -- what about
`touchscreen technology were you deposed upon,
`or did you opine on?
` A. It was litigation in the ITC between
`Apple and HTC. The patent at issue was -- it
`was a capacitive touchscreen that had shield --
`that had shield lines. It was one of the Apple
`patents that was asserted against HTC.
` Q. Do you understand you are under oath
`today?
` A. Yes.
` Q. I will be asking you questions during
`this deposition, you will be giving me some --
`you know, your answers. The court reporter
`will be transcribing them, so when you speak,
`just, you know, speak loudly and clearly so
`that she can hear it and, you know, she can
`transcribe them accurately.
` During this deposition, we will be
`taking breaks, and, you know, if you need a,
`you know, break before I schedule one, just
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` please let us know and, you know, we will be
` happy to take it. But, you know, to the extent
` that a question is pending, let's, you know,
` finish the question and then we can take a
` break.
` During this deposition, your lawyer
` may object but you should answer any -- you
` know, anyways unless your counsel instructs you
` not to answer the question. Do you understand
` that?
` A. I understand.
` Q. Okay. If a question is not clear,
` just please let me know; otherwise, I'll assume
` that you understood it.
` A. Okay.
` Q. Just for a clean -- you know, for
` purposes of a clean transcript, let's try and
` not speak over each other. So I'll make sure
` that I do not, you know, interrupt you and if
` you would extend me the same courtesy.
` A. Okay.
` Q. Okay. Any questions before we get
` started?
` A. No.
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` Q. Any reason you cannot testify
` completely and accurately today?
` A. No.
` Q. Dr. Cairns, did you prepare for this
` deposition?
` A. Yes.
` Q. What did you do as part of your
` preparation?
` MS. SUMMERS: I'd just advise
` Dr. Cairns to not discuss any privileged
` information, but you may answer.
` A. I met with counsel and I reviewed the
` expert reports that I prepared in this case and
` the documents that I considered as part of
` preparing my expert reports.
` Q. Which documents did you look at?
` A. I looked at the patents and I looked
` at the institution decision for the -- for the
` IPR.
` Q. When you say looked at the patents,
` do you mean the '183 patent?
` A. The '183 patent and the Caldwell
` patent and the Ingraham I patent and the
` Gerpheide patent. The patents that are
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` referenced in the -- in the expert reports.
` Q. Anything else that you looked at in
` preparation for this deposition?
` A. I don't believe so.
` Q. Roughly how long did you prepare for
` this deposition?
` A. I met with counsel for about --
` not -- about -- yesterday, about -- the morning
` and the afternoon yesterday.
` Q. So other than your meeting with, you
` know, with counsel, did you spend additional
` time reviewing your declaration and the other
` documents?
` A. A few hours.
` Q. Did you bring anything with you today
` to help you testify?
` A. No.
` Q. Do you understand that UUSI has sued
` Samsung for infringement for the '183 patent?
` MS. SUMMERS: Objection, outside
` the scope of the expert report.
` A. I understand that there's -- it's my
` understanding that there's litigation between
` UUSI and Samsung. It's my understanding that
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` that's -- that that's why there's an IPR, that
` that was -- that during the litigation, that an
` IPR was filed. And that's what I know.
` Q. Do you know which products were
` accused of infringement --
` MS. SUMMERS: Objection,
` irrelevant.
` Q. -- in this litigation?
` MS. SUMMERS: Objection,
` irrelevant, outside the scope.
` A. No.
` Q. Do you know the claim construction
` positions that both parties proposed in the
` District Court litigation?
` MS. SUMMERS: Objection, relevance.
` A. The only thing that I know is what I
` said in the expert report. So I believe that
` there may be some reference in the expert
` report to some claim construction positions
` that are related to the District Court
` positions, and there may have been some mention
` in the -- in the institution decision. I don't
` remember whether they mentioned -- whether they
` mentioned that. And that's -- that's the
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`extent of my knowledge on any claim
`construction positions in the litigation.
` Q. Have you seen the infringement
`contentions that UUSI submitted to Samsung
`accusing it of infringement?
` MS. SUMMERS: Objection, relevance,
` outside the scope of the expert report.
` A. No.
` Q. Dr. Cairns, I want to spend the next
`few minutes generally understanding your
`background. So turn to your CV. Could you
`just briefly walk me through your CV, that is,
`you know, where you went to, you know,
`undergrad, graduate school, what you did after
`graduate school, just sort of in sequential
`order.
` A. Do you have a copy of my CV to make
`that a little easier?
` MR. BANSAL: Sure. I'm going to
` hand you what has been previously marked
` in this proceeding as Exhibit 2003.
` (Exhibit No. 2003, previously marked, was
` referenced and indexed.)
`BY MR. BANSAL:
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` Q. Do you recognize this exhibit,
`Dr. Cairns?
` A. Yes.
` Q. What is it?
` A. It's a copy of my CV.
` Q. So maybe -- do you want to start me
`off with your graduate work at the University
`of Birmingham, UK?
` A. Yes. So my graduate work was on
`optical fibers for telecommunication networks,
`and specifically, it was the reliability of
`optical fibers. And I worked with Pirelli
`cables.
` Q. And then you moved over to Brown
`University as a postdoctoral researcher?
` A. Yes.
` Q. And what did you do as part of your
`postdoctoral research?
` A. I worked in the display laboratory at
`Brown University. I worked on flexible
`displays and electro-optical materials for
`displays on other devices, so predominantly
`liquid crystal based materials and devices and
`flexible displays.
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` Q. I see. So your work involved sort of
`the manufacturing -- sorry, manufacturability
`of the displays, strength of the display,
`flexibility? Is that what your research was
`focused on?
` A. My research was focused on making
`working devices that were displays, and as part
`of that, some of the things that I published on
`were to do with the issues to do with the
`manufacturing of displays. But it was -- it
`was the entirety of making working devices.
` Q. Then you moved over to 3M Touch
`Systems in 2001; right?
` A. Yes.
` Q. What did you do over there?
` A. I worked on touchscreen technologies,
`specifically I worked on capacitive and
`resistive touchscreens, including flexible
`touchscreens, touchscreens that were -- that
`had thin cover sheets. In general, capacitive
`touchscreens, with some work on resistive
`touchscreens.
` Q. So you were concerned with the
`materials used for these touchscreens?
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` A. I did some -- I did some work on
`materials. I also -- but I worked on the
`entirety of making functioning sensors.
` Q. Did you publish any papers while you
`were at 3M?
` A. I published patents when I was at 3M.
`I did publish some papers while I was at 3M. I
`don't recall whether they were on things that I
`did at 3M. They may have been on things that
`I'd done at Brown. But in general while
`working at 3M, lots of what you worked on
`there, they don't want -- necessarily want in
`the public domain.
` Q. While you were at 3M, were you
`involved with the circuit design of capacitive
`touch sensors?
` A. I was involved with the sensor design
`and integrating the sensor with electronics and
`with ensuring that the sensors would work
`efficiently.
` Q. When you say a sensor, you mean what?
` A. When I say -- when I say sensor, in
`response to -- it's the hardware that senses
`the touch. So it's -- it's the -- it's what
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`you physically touch and how that integrates
`with the controller. So it's everything, but
`primarily, I worked on the -- primarily I
`worked on the sensor.
` Q. Did you work on the circuitry of the
`sensor, the design of the circuitry of the
`sensor?
` A. Did I design the circuitry? No. And
`let me clarify. When you say on the -- the
`circuitry that might be on the sensor which
`would include the electrode pattern that's
`around the outside, those things I worked on.
`If you're saying the ASIC, I didn't do ASIC
`design, no.
` Q. So let me understand.
` Usually in a capacitive touch sensor
`you have the electrode arrays; right?
` A. You would -- you could have an
`electrode array or it could be -- or it could
`be a continuous sheet with some sort of
`patterning around the edge to make the electric
`field uniform.
` Q. And then there would be some analog
`circuitry that senses the capacitance change on
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`the electrode array or your sheet?
` A. And some firmware that would be --
`that would be used to interpret that. So I
`would use the controller and I would use the
`firmware, and my work -- and I would work
`mostly on the sensor part, the electrode
`pattern -- yeah.
` Q. But you did not design any of the --
`any of the circuitry that actually senses what
`the electrodes sense?
` MS. SUMMERS: Objection, relevance.
` A. If you're asking did I design any of
`the circuitry in any of the controllers that 3M
`used at the time, no.
` Q. Also, the characteristics of the
`touchscreen technology that you described, was
`it at the time of the invention of the '183
`patent or today?
` MS. SUMMERS: Objection, relevance.
` A. I'm not completely sure what you mean
`by the question and what you mean by "today."
` Q. Just -- so by "today" I mean the time
`you signed your declaration in this proceeding.
` A. Maybe if you could repeat or rephrase
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`the question.
` Q. Okay. Actually, I will withdraw that
`question.
` So I see you have a lot of papers
`in -- tons of conference papers, journal
`papers, patents. Do any of those deal with
`circuit design of capacitive touch sensors?
` A. Do any of them deal with -- some of
`them deal with the sensors and the operation of
`the sensors. But if you're asking are any of
`them specifically on designing the -- an ASIC,
`no, it's not on the ASIC but it is -- there are
`some on the sensor design, including the
`operation of the sensor.
` Q. Did you -- as part of your graduate
`work at University of Birmingham, did you take
`any graduate level courses on ASIC design?
` A. On ASIC design? No. It's hard to
`equate the UK education system with the US
`education system in terms of some of the
`classes that I took as an undergraduate. So I
`took electronics classes as part of my
`undergraduate program, and they might be
`considered graduate level classes in the US.
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`It's hard to equate those sometimes. But in my
`graduate studies, no, I did not.
` Q. So as part of undergraduate work, how
`many classes did you take on circuit design?
` A. I think maybe three.
` Q. Do you remember your favorite book
`from those classes?
` A. What?
` Q. Your favorite book on circuit design
`from those classes?
` MS. SUMMERS: Objection,
` irrelevant.
` A. Oh, I don't -- I don't know. And
`it -- no, I don't -- I don't recall.
` Q. I mean, so as -- you know, as part of
`your work from 2001 through now, have you been
`involved in any circuit design for capacitive
`touch sensors?
` MS. SUMMERS: Objection,
` irrelevant.
` A. Individually, I have not been
`involved in circuit design, but I have been
`involved in sensor design.
` MR. BANSAL: I want to hand you
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` what has been previously marked as
` Exhibit 1001 in this proceeding.
` (Exhibit No. 1001, previously marked, was
` referenced and indexed.)
`BY MR. BANSAL:
` Q. Do you recognize this exhibit,
`Dr. Cairns?
` A. Yes. It's the '183 patent.
` Q. Could you please turn to figure
`number 8 for this patent?
` A. I have it.
` Q. Could you generally describe for me
`how this circuit works?
` Actually, before you do that, what is
`the circuit described in figure 8? Is it a
`touch circuit?
` A. The patent refers to it as a touch
`circuit.
` Q. Do you agree that it's a touch
`circuit?
` A. I mean, that's what it says.
` Q. Would you describe for me the
`operation of figure 8?
` A. So when somebody touches the circuit
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`near the -- on 450, which is not shown, but
`by -- near 451 on figure 8, the capacitance of
`the user touching it and the path to ground
`allow the -- allow for a signal to go -- to
`pass through the transistor 410, and when you
`touch it above it, it goes above a threshold
`value of capacitance, then a transistor
`conducts and it goes to a -- and it gives a
`positive -- it -- it goes to a positive state
`so it goes -- it switches on or off depending
`on whether you touch at 451.
` Q. So let me understand this. When a
`user touches that touch circuit of 400, does
`the user physically touch terminal 451?
` A. No.
` Q. Then what does the user touch?
` A. With reference to figure 4, they
`touch the touch pad 450, which is connected
`through line 451 to touch circuit 400, which is
`what's shown in figure 8.
` Q. So does the touch pad act like an
`insulator?
` A. I don't understand the question.
` Q. Is the touch pad 450 an insulator?
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` MS. SUMMERS: Objection, form.
` A. I still don't understand the
`question.
` Q. What don't you understand about it?
` A. So at least part of the touch pad 450
`is a conductor, but -- the way that I
`understand it is that it -- it's a conductor
`but it may have an insulating layer on top of
`the conductor.
` Q. The touch pad 450 is going to be
`electrically connected to terminal 451?
` A. Yes.
` Q. When the user touches the touch pad
`450, what is the voltage on terminal 451?
` MS. SUMMERS: Objection, form.
` Q. Let me rephrase that for you,
`Dr. Cairns. When a user touches the touch pad
`450, does it result in a drop of voltage on
`terminal 451?
` MS. SUMMERS: Objection, form.
` A. It could.
` Q. So in the '183 patent, if a user
`touches a touch pad, it is possible that the
`associated touch circuit, terminal 451, will
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`not have a decrease in voltage?
` MS. SUMMERS: Objection, misstates
` prior testimony.
` A. To some extent, whether you would see
`an increase in the voltage or a decrease in the
`voltage could -- would depend upon the sensor
`design. So, for example, if it was an
`individual touch pad, the voltage may drop. If
`you have more than one -- if you have multiple
`conductors linked together, then you could see
`an increase. So it depends on how you
`configure the sensor portion or configure the
`touch pad portion.
` Q. How does the '183 patent configure
`the touch pad portion?
` A. For -- if we're talking about the
`claims at issue, then it -- then there could be
`either. It could be -- it could detect both
`ways.
` Q. Dr. Cairns, with respect to the
`disclosure of figure 8 of the '183 patent, what
`does the '183 patent say happens when a user
`touches the touch pad of the circuit of 400?
` MS. SUMMERS: Objection, asked and
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` answered.
` A. Is there a particular section in the
`'183?
` Q. Well, I'm just -- because you said
`that depending on the configuration, the
`voltage at point 451 could either increase or
`decrease, I'm asking you what is the
`configuration that's actually disclosed in the
`'183 patent?
` MS. SUMMERS: Objection, asked and
` answered; misstates prior testimony.
` A. Well -- so for the purpose of the
`claims, I haven't really considered that. It
`wasn't -- it wasn't part of my analysis as to
`what the implications of that would be.
` Q. Dr. Cairns, I'm not asking you about
`the claims at this point. Let me maybe help
`you here. Can you point me to a -- actually,
`before I do that, let me just -- could you
`please look at column 15, lines 37 through 41
`of the '183 patent?
` A. Okay.
` Q. What does that portion tell you?
`Actually, let me rephrase my question.
`
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` D. Cairns
` Does that portion tell you that when
`a user touches a touch pad, the voltage at node
`451 will decrease?
` MS. SUMMERS: Objection, outside
` the scope of the expert report.
` A. It doesn't mention what happens at
`node 451.
` Q. Does it mention what happens at the
`base of the transistor 410?
` MS. SUMMERS: Objection, outside
` the scope.
` A. Yes.
` Q. Is the base of transistor 410
`connected to terminal 451?
` A. Yes.
` Q. So if the base of transistor 410 has
`to go down in voltage, is it necessary for
`terminal 451 to also go down in voltage?
` MS. SUMMERS: Objection, form.
` Outside the scope.
` A. As described in this section of the
`patent, that's what it's describing in this
`section of the patent.
` Q. So then you agree that when a user
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` D. Cairns
`touches a touch pad as described in the '183
`patent, the voltage at node 451 goes down?
` MS. SUMMERS: Misrepresents prior
` testimony.
` A. As -- as I said, whether the voltage
`would go up or down could depend on the sensor
`construction, whether any touch pads are
`connected to other touch pads. But in the
`example that's described with reference to
`figure 8, it does go down when it -- what
`they're describing is the voltage goes down at
`the base of the transistor when it's touched.
` Q. Is there any place in the '183 patent
`where it is described that the voltage at 451
`goes up when the user touches the touch pad?
` MS. SUMMERS: Objection, outside
` the scope of the expert report;
` irrelevant.
` A. I don't -- I don't recall. I
`didn't -- it wasn't something that -- that I
`looked for in my analysis of the claims at
`issue.
` Q. Sitting here today, you do not recall
`any section of the '183 patent which discloses
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` D. Cairns
`that when a user touches the touch pad,
`terminal 451 goes up in voltage?
` MS. SUMMERS: Same objections;
` asked and answered.
` A. So there's a section in column 18,
`line 34 and onwards -- I don't recall -- that
`describes the operation of the -- the multiple
`touch pads shown in figure 11, which uses
`elements of what's shown in figures 4 and 8.
` And one of the things that it
`describes in there is that -- maybe from 39 --
`that "The multiple touch pad circuit is a
`variation of the first embodiment in that it
`includes an array of touch circuits designated
`as 900 through 900nm, which, as shown, include
`both the touch circuit 400 shown in figures 4
`and 8 and the -- and the input touch terminal
`pad 451 in figure 4. Microcontroller 500
`selects each row of the touch circuits 900
`and -- 900 subscript 1 to 900 subscript nm by
`providing the signal from oscillator 200 to
`selected rows of touch circuits. In this
`manner, microcontroller 500 can sequentially
`activate the touch circuit rows and associate
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` D. Cairns
`the received input from the columns of the
`array with the activated touch circuits."
` So to the extent that you have a
`signal passing along rows and then read them on
`columns, where that -- which would create a
`parallel capacitor, in that case, the voltage
`may go up.
` Q. Let me understand this.
` If a user touches a touch pad and the
`voltage at 451 goes up, will the touch circuit
`of figure 8 detect that the user has actually
`touched the touch pad?
` MS. SUMMERS: Objection, outside
` the scope of the expert report.
` A. I haven't considered that in detail.
`I just was pointing to an area in response to
`the previous question where it shows that there
`was -- where you could tie multiple lines
`together which would result in a -- where you
`may see an increase in the signal in response
`to a touch.
` Q. I want to focus on figure 8, though,
`Dr. Cairns. If a user touches a touch pad and
`the voltage at 451 goes up, will transistor 410
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` D. Cairns
`turn on?
` MS. SUMMERS: Objection, outside
` the scope.
` A. I haven't thought about that.
` Q. What causes transistor 410 to turn
`on, Professor?
` MS. SUMMERS: Objection, vague.
` A. A change in the voltage at the base
`of the transistor.
` Q. Compared to what? Actually, let me
`back up.
` What -- what needs to happen to the
`base -- let me rephrase that.
` If the voltage -- sorry -- if the
`voltage at terminal 451 goes up, does the base
`voltage of transistor 410 go up?
` MS. SUMMERS: Objection, outside
` the scope. Objection, form.
` A. If you're asking based on the
`circuit, yes.
` Q. Can transistor 410 turn on if the
`base voltage of 410 goes up?
` A. As it's drawn there, no.
` Q. Which means that in order for 410 to
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` D. Cairns
`turn on, the voltage at the base terminal of
`410 has to go down?
` MS. SUMMERS: Objection, misstates
` prior testimony; outside the scope of
` the expert report.
` A. I mean, I haven't -- I haven't
`thought about it.
` Q. Can you think about it now?
` MS. SUMMERS: Objection, outside
` the scope of the expert report;
` relevance.
` A. You're going to have to remind me
`what the question was.
` Q. In order for transistor 410 to turn
`on, does the voltage at the base terminal of
`410 have to go down?
` MS. SUMMERS: Same objections.
` A. For the circuit that's drawn in
`figure 8, yes.
` Q. Is there another configuration of the
`circuit of figure 8 in the '183 patent?
` MS. SUMMERS: Objection, relevance.
` Objection, outside the scope.
` A. So in the same section that I
`
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` D. Cairns
`mentioned -- that we mentioned previously in
`column 18, line 34, it describes -- it says
`that in "a multiple touch pad circuit
`constructed in accordance with the second
`embodiment, components similar to those in the
`first embodiment in figure 4 are designated
`with the same reference numeral and will not be
`discussed in detail. The multiple touch pad
`circuit is a variation of the first embodiment
`in that it includes an array of touch circuits
`designated as 900 subscript 1 through 900nm."
` So there's some discussion that
`it's -- the components are similar but it's --
`in there and I haven't considered in detail
`whether, you know, it would -- whether it would
`operate differently.
` Q. In the '183 patent, is there any
`other circuit configuration for the touch
`circuit other than figure 8?
` MS. SUMMERS: Objection, asked and
` answered; outside the scope of the
` expert report.
` A. There are other figures that are
`designated as different embodiments. There are
`
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` D. Cairns
`some areas like I mention in the specification
`that talk about that. And because it wasn't
`relevant to my analysis for this proceeding, I
`haven't considered, you know, what may or may
`not be in the specification regarding the touch
`circuit itself. In terms of alternatives, I
`haven't considered alternatives.
` Q. So going back to figure 8, do you see
`line 201 in figure 8?
` A. Yes.
` Q. What's the voltage on line 201 in
`figure 8?
` MS. SUMMERS: Objection, form.
` Objection, relevance.
` A. Is there an area in this -- I don't
`remember.
` Q. Column 14, lines 3 to 4.
` A. 26 volts peak to peak.
` Q. So the voltage on line 26 -- sorry,
`so the voltage on line 201 is 26 volts peak to
`peak?
` A. Yeah. And I'm just going to -- it
`says "peak square wave." I can't remember
`whether it's peak to peak, but I think that's
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`the way that they did it.
` Q. Just out of curiosity, if a user
`touches a touch pad, wouldn't the user get
`26 volts across him because 26-volt signal is
`being applied to line 201?
` MS. SUMMERS: Objection, relevance.
` Objection, outside the scope of the
` expert report.
` A. I haven't thought about that.
` Q. Can you think about it now?
` MS. SUMMERS: Same objections.
` A. I -- I don't know.
` MS. SUMMERS: We have been going
` for about an hour now. Are you in a
` good place?
` SPEAKER FOUR: Up to you.
` MR. BANSAL: I'm okay if you want
` to -- let's take a five-minute break.
` How about that.
` THE WITNESS: Oh, sure, yeah.
` (Recess taken.)
`BY MR. BANSAL:
` Q. Dr. Cairns, during the break did you
`talk to your attorney?
`
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` A. No.
` Q. I want to go back to my last
`question, Dr. Cairns. When a user touches the
`touch pad, what is the voltage that the user
`feels?
` MS. SUMMERS: Objection, outside
` the scope of the expert report.
` Objection, form.
` Counsel, could you please show me
` where in the expert report this lin

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