ZANE COLEMAN, Ph.D.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` 5
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` 6
`
` vs.
`
` 3 TECHNICAL CONSUMER )
` PRODUCTS, INC., NICOR )
` 4 INC., and AMAX
` )
` LIGHTING,
` )
` ) No. IPR2017-01280
` Petitioners, )
` ) No. IPR2017-01285
` )
` ) No. IPR2017-01287
` LIGHTING SCIENCE GROUP )
` 8 CORP.,
` )
` )
` Patent Owner. )
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`10
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`11
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` The deposition of ZANE COLEMAN, Ph.D.,
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`12 called by the Patent Owner for examination, pursuant
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`13 to Notice, and pursuant to the Rules of Civil
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`14 Procedure for the United States District Courts,
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`15 taken before Sandra L. Rocca, CSR License No.
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`16
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`084-003435, CRR, at 233 SouthWacker Drive, Chicago,
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`17 Illinois, on the 17th of January, 2018, at the hour
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`18 of 8:49 a.m.
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`PATENT OWNER EXHIBIT 2002
`Page 1
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` 1
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` 2
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` 5
`
` 6
`
` vs.
`
` 3 TECHNICAL CONSUMER )
` PRODUCTS, INC., NICOR )
` 4 INC., and AMAX
` )
` LIGHTING,
` )
` ) No. IPR2017-01280
` Petitioners, )
` ) No. IPR2017-01285
` )
` ) No. IPR2017-01287
` LIGHTING SCIENCE GROUP )
` 8 CORP.,
` )
` )
` Patent Owner. )
`
` 7
`
` 9
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`10
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`11
`
` The deposition of ZANE COLEMAN, Ph.D.,
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`12 called by the Patent Owner for examination, pursuant
`
`13 to Notice, and pursuant to the Rules of Civil
`
`14 Procedure for the United States District Courts,
`
`15 taken before Sandra L. Rocca, CSR License No.
`
`16
`
`084-003435, CRR, at 233 SouthWacker Drive, Chicago,
`
`17 Illinois, on the 17th of January, 2018, at the hour
`
`18 of 8:49 a.m.
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`19
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`20
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`21
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`22
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`PATENT OWNER EXHIBIT 2002
`Page 1
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`ZANE COLEMAN, Ph.D.
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` 1 APPEARANCES:
`
` 2
` SCHIFF HARDIN LLP
` 3 By: MS. STACIE R. HARTMAN
` MR. THOMAS A. RAMMER, II
` 4 233 South Wacker Drive, Suite 6600
` Chicago, IL 60606
` 5 312.498.7880
` shartman@schiffhardin.com
` 6 trammer@schiffhardin.com
`
` 7 appeared on behalf of the
` Petitioners;
` 8
`
` 9
` KIRKLAND & ELLIS LLP
`10 By: MR. ERIC D. HAYES
` 300 North LaSalle Street
`11 Chicago, Illinois 60654
` 312.862.2480
`12 eric.hayes@kirkland.com
`
`13 appeared on behalf of the
` Patent Owner.
`14
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`15
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`16
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`17
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`PATENT OWNER EXHIBIT 2002
`Page 2
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`ZANE COLEMAN, Ph.D.
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` 1 I N D E X
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` 2 WITNESS PAGE
`
` 3 ZANE COLEMAN, Ph.D.
`
` 4 EXAMINED BY
`
` 5 Mr. Hayes 5
` Mr. Rammer 52
` 6 Mr. Hayes 53
`
` 7
`
` 8 EXHIBITS
`
` 9 NUMBER MARKED FOR ID
`
`10 Coleman
`
`11 Exhibit 1 Z. Coleman declaration re
` U.S. Patent Number 8,201,968 4
`12
` Exhibit 2 Z. Coleman declaration re
`13 U.S. Patent Number 8,967,844 4
`
`14 Exhibit 3 Z. Coleman declaration re
` U.S. Coleman Number 8,672,518 4
`15
` Exhibit 4 U.S. Patent Number 8,201,968 4
`16
` Exhibit 5 U.S. Patent Number 8,967,844 5
`17
` Exhibit 6 U.S. Patent Number 8,672,518 5
`18
` Exhibit 7 U.S. Patent Number 7,670,021 16
`19
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`20
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`21
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`22
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`24
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`3
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`PATENT OWNER EXHIBIT 2002
`Page 3
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`ZANE COLEMAN, Ph.D.
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` 1 (Witness sworn.)
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` 2 MR. HAYES: For the record, we'll mark your
`
` 3 declaration in the '968 patent IPR as Exhibit 1.
`
` 4 (Coleman Exhibit 1 marked for
`
` 5 identification.).
`
` 6 MR. HAYES: And then for the record, we will
`
` 7 mark your declaration for the '844 patent IPR as
`
` 8 Exhibit 2.
`
` 9 (Coleman Exhibit 2 marked for
`
`10 identification.)
`
`11 MR. HAYES: And then we'll mark for the
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`12 record as Exhibit 3, Dr. Coleman's declaration for
`
`13 the '518 patent IPR.
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`14 (Coleman Exhibit 3 marked for
`
`15 identification.)
`
`16 MR. HAYES: For the record, we will mark the
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`17 '968 patent as Exhibit 4.
`
`18 (Coleman Exhibit 4 marked for
`
`19 identification.)
`
`20 MR. HAYES: Dr. Coleman, you're comfortable
`
`21 if I refer to the patents by their last three
`
`22 numbers?
`
`23 THE WITNESS: Yes.
`
`24 MR. HAYES: And then we'll mark -- for the
`
`25 record we will mark as Exhibit 5, the '844 patent.
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`4
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`PATENT OWNER EXHIBIT 2002
`Page 4
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`ZANE COLEMAN, Ph.D.
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` 1 (Coleman Exhibit 5 marked for
`
` 2 identification.)
`
` 3 MR. HAYES: Let's mark for the record as
`
` 4 Exhibit 6, the '518 patent.
`
` 5 (Coleman Exhibit 6 marked for
`
` 6 identification.)
`
` 7 ZANE COLEMAN, Ph.D.,
`
` 8 having been first duly sworn, was examined and
`
` 9 testified as follows:
`
`10 CROSS EXAMINATION
`
`11 BY MR. HAYES:
`
`12 Q Okay. Good morning, Dr. Coleman.
`
`13 A Morning.
`
`14 Q Thanks for being here. Is there any reason,
`
`15 medication, illness or otherwise, that you can't
`
`16 answer my questions fully and truthfully today?
`
`17 A No. I will say that I may have a head cold
`
`18 or flu coming on.
`
`19 Q So if you don't hear a question or
`
`20 understand, just let me know.
`
`21 A Okay.
`
`22 Q Exhibit 1 is your declaration with respect
`
`23 to the '968 patent IPR. Dr. Coleman, does Exhibit 1
`
`24 contain all of your opinions in this case with
`
`25 respect to the '968 IPR?
`
`5
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`PATENT OWNER EXHIBIT 2002
`Page 5
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`ZANE COLEMAN, Ph.D.
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` 1 A Yes.
`
` 2 Q And Dr. Coleman, Exhibit 2 is your
`
` 3 declaration with respect to the '844 patent IPR.
`
` 4 Does Exhibit 2 contain all of your opinions with
`
` 5 respect to the '844 IPR in this case?
`
` 6 A It contains all my opinions related to the
`
` 7 arguments I made. There may --
`
` 8 Q With respect to the '844 patent?
`
` 9 A Right.
`
`10 Q Okay. I'm just asking do you have any other
`
`11 opinions in this case with respect to the '844 IPR
`
`12 that are not contained in your declaration?
`
`13 A These are my opinions related to the -- and
`
`14 all the grounds. If you'd like to ask me other
`
`15 questions, there could be other opinions.
`
`16 Q So sitting here today, do you have other
`
`17 opinions?
`
`18 A No.
`
`19 Q And then with respect to Exhibit 3, which is
`
`20 your declaration for the '518 patent IPR, does
`
`21 Exhibit 3 include all your opinions in this case
`
`22 with respect to the '518 patent IPR?
`
`23 A It includes all my opinions. There are some
`
`24 clarifications.
`
`25 Q What are those clarifications?
`
`6
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`PATENT OWNER EXHIBIT 2002
`Page 6
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`ZANE COLEMAN, Ph.D.
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` 1 A In Ground 3, it was implied -- in Ground 3,
`
` 2 with respect to Claim 10, it was implied that
`
` 3 Claim 10 was obvious by Soderman in light of Wegner
`
` 4 and Barnett and/or Van Elmpt. And likewise, Claim 6
`
` 5 was obvious by Zhang in light of Wegner and Barnett
`
` 6 or Van Elmpt, just for clarification.
`
` 7 Q But those are implied opinions, those are
`
` 8 not set forth in your declaration, is that right?
`
` 9 A The information is in there and my
`
`10 discussion of Wegner is disclosed in there and the
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`11 reasoning.
`
`12 Q Okay. So in addition to these two implied
`
`13 opinions, anything else with respect to '518?
`
`14 MS. HARTMAN: I object to the form of the
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`15 question.
`
`16 THE WITNESS: I wouldn't designate these as
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`17 implied opinions. My opinions are in there that --
`
`18 of the obviousness in light of Wegner. They are not
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`19 explicitly stated.
`
`20 Q Any other opinions that are not explicitly
`
`21 stated in your declaration or declarations?
`
`22 A There is another clarification on page 51 of
`
`23 the '518 declaration, paragraph 77.
`
`24 Q Okay.
`
`25 A To be more clear, it should read, the wire
`
`7
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`PATENT OWNER EXHIBIT 2002
`Page 7
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`ZANE COLEMAN, Ph.D.
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` 1 64 connected to the driver, i.e. power conditioner,
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` 2 which is connected via connector 68 to the LEDs. It
`
` 3 is written more clearly in the '944 declaration --
`
` 4 I'm sorry, the '844 declaration.
`
` 5 Q You kind of said that quickly. So you want
`
` 6 it to read the wire 64 connected to the driver and
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` 7 then insert, which is connected?
`
` 8 A Correct, which is connected via connector 68
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` 9 to the LEDs.
`
`10 Q Okay. So just to make sure we have it for
`
`11 the record there, paragraph 77 on page 51 of
`
`12 Exhibit 3, which is the '518 declaration, you want
`
`13 the last -- you want what appears to be the last
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`14 sentence on page 51, paragraph 77 to read, the wire
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`15 64 connected to the driver which is connected via
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`16 connector 68 to the LEDs?
`
`17 A Correct.
`
`18 Q Anything else?
`
`19 A That's all I can recall at this moment.
`
`20 Q Okay. What's your understanding of a heat
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`21 sink in the context of these three IPRs?
`
`22 A A heat sink is a component that dissipates
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`23 heat into the environment.
`
`24 Q What's your understanding of a heat spreader
`
`25 in the context of these three IPRs?
`
`8
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`PATENT OWNER EXHIBIT 2002
`Page 8
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`ZANE COLEMAN, Ph.D.
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` 1 A A heat spreader is a component that
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` 2 transfers heat to another component.
`
` 3 Q So is it your understanding that the
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` 4 difference between a heat sink and a heat spreader
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` 5 in this context is that the heat sink dissipates
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` 6 heat to the environment and the heat spreader
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` 7 transfers heat to another component, not the
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` 8 environment, is that fair?
`
` 9 A I would repeat what I said, that the heat
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`10 sink transfers heat -- the heat sink dissipates heat
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`11 to the environment and the heat spreader transfers
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`12 heat to another component.
`
`13 Q Prior to your work on these three cases,
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`14 '968, '844 and '518 IPRs, were you familiar with the
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`15 term heat spreader?
`
`16 A Yes.
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`17 Q In what context?
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`18 A It was used and it's a common term used
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`19 initially with a lot of computer chips for spreading
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`20 the heat off of a computer chip onto a heat sink.
`
`21 Q Would you agree that a vertically oriented
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`22 heat sink is more efficient than a horizontally
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`23 oriented heat sink?
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`24 A It would depend on the configuration of the
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`25 heat sink and the environment.
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`9
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`PATENT OWNER EXHIBIT 2002
`Page 9
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`ZANE COLEMAN, Ph.D.
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` 1 Q All else being equal, with respect to the
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` 2 configuration and the environment -- let me be a
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` 3 little more specific.
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` 4 Is a vertically oriented fin on a heat sink
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` 5 a more efficient transfer of heat than a
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` 6 horizontally aligned fin on a heat sink?
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` 7 A The efficiency of the heat sink would depend
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` 8 on numerous variables in the environment and would
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` 9 require complex modeling to determine the actual
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`10 efficiency and relate to the actual design, shape,
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`11 structure, length and then the environmental
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`12 variables to determine efficiency of the heat sink
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`13 fin.
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`14 Q But if we kind of normalize out all of those
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`15 other variables, environment -- and let's just focus
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`16 on one fin-shaped heat sink. If I orient it -- put
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`17 the axis in a vertical direction, is that, you know,
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`18 vertically oriented fin on the heat sink more
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`19 efficient than transferring heat as compared to me
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`20 rotating that heat sink 90 degrees so that the fin
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`21 is in a horizontal direction?
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`22 MS. HARTMAN: Object to form and incomplete
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`23 hypothetical.
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`24 THE WITNESS: It would depend on the
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`25 configuration. The efficiency of the heat sink is
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`10
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`PATENT OWNER EXHIBIT 2002
`Page 10
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`ZANE COLEMAN, Ph.D.
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` 1 related to the ambient environment and air flow
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` 2 around the fin, for example.
`
` 3 Q In performing your analysis with respect to
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` 4 these three IPRs, the '968, '844 and '518, did you
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` 5 consider the angle of the surface of each of the
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` 6 heat transfer fins?
`
` 7 A I'm sorry. Could you be more specific?
`
` 8 Q Yeah, in performing your analysis in these
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` 9 three IPRs, did you consider the angle or the
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`10 orientation of the surface of the heat sinks that
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`11 you were analyzing?
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`12 A With respect to -- I'm trying to understand
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`13 the context.
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`14 Q Any of the prior art or patents that you
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`15 looked at in this case.
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`16 A I'm not sure I'm understanding your
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`17 question. My analysis was with respect to
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`18 anticipation and obviousness of the LSG patents.
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`19 Q In that context of doing your anticipation
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`20 and obviousness of the LSG patents, you looked at a
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`21 number of pieces of prior art that include heat
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`22 sinks, correct?
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`23 A Yes.
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`24 Q So kind of in the context of your analysis
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`25 of anticipation and obviousness, did you consider --
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`11
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`PATENT OWNER EXHIBIT 2002
`Page 11
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`ZANE COLEMAN, Ph.D.
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` 1 I didn't see it anywhere in your declarations, but
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` 2 did you consider the angles of the surfaces that you
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` 3 were looking at?
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` 4 A That were claims that referenced fins and
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` 5 recesses, which would inherently have angles.
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` 6 Q In the context of those claims that
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` 7 reference fins and recesses, did you analyze the
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` 8 angles of the fins, if you will?
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` 9 A I don't recall an angle being specified in a
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`10 claim.
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`11 Q Okay. So is the answer no?
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`12 A The answer is I don't recall an angle being
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`13 specified in a claim for a claim analysis.
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`14 Q So I mean, I didn't see anywhere in your
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`15 declarations that you ever kind of talked about the
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`16 angle of the fins, for example, in relation to the
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`17 X/Y axis or any other axis, is that fair?
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`18 MS. HARTMAN: Object to form.
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`19 THE WITNESS: I don't recall discussing the
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`20 angle of the fins in my declarations specifically.
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`21 Q What is a Nusselt number?
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`22 A I'm sorry?
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`23 Q What is a Nusselt number, n-u-s-s-e-l-t?
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`24 A Right here and right now, I can't think of
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`25 what that refers to.
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`12
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`PATENT OWNER EXHIBIT 2002
`Page 12
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`ZANE COLEMAN, Ph.D.
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` 1 Q Would you agree that water is a better heat
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` 2 transfer medium than air?
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` 3 MS. HARTMAN: Objection, relevance.
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` 4 THE WITNESS: It can be.
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` 5 Q In what instances is water not a better heat
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` 6 transfer medium than air?
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` 7 A For example, if the water was very hot.
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` 8 Q As compared to the air, is that what you're
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` 9 saying?
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`10 A In that example.
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`11 Q Okay. Any others?
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`12 A I can't recall any additional right now at
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`13 this time.
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`14 Q So if we kind of take out this idea that the
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`15 water is hot, if you're passing water and air over a
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`16 heat source and the water and the air that you're
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`17 passing over the heat source are the same
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`18 temperature, would you agree that water is a better
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`19 medium -- transfer medium than air?
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`20 MS. HARTMAN: Objection, relevance.
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`21 THE WITNESS: I'm not sure I understand the
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`22 context of your question.
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`23 Q You understand the difference between
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`24 convection and conduction, right?
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`25 A Yes.
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`13
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`PATENT OWNER EXHIBIT 2002
`Page 13
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`ZANE COLEMAN, Ph.D.
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` 1 Q Is conduction a more efficient means of
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` 2 transferring heat than convection, generally
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` 3 speaking?
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` 4 MS. HARTMAN: Objection, relevance.
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` 5 THE WITNESS: Generally speaking, conduction
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` 6 is more effective than convection, all things being
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` 7 equal.
`
` 8 Q Would you agree that one of the reasons --
`
` 9 or it's important to transfer heat away from LEDs
`
`10 because the warmer generally LEDs are over the life,
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`11 the shorter of life span of the LEDs?
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`12 MS. HARTMAN: Objection, form.
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`13 THE WITNESS: That is one potential effect.
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`14 Q Would you agree that, generally speaking,
`
`15 all else equal, the temperature or the amount of
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`16 heat in an LED packet over its life span is kind of
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`17 inversely related to the life of the LED package?
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`18 In other words, the warmer the LEDs, the shorter the
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`19 life span?
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`20 MS. HARTMAN: Objection, form, incomplete
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`21 hypothetical.
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`22 THE WITNESS: It is my understanding right
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`23 here right now, it would depend on how warm is warm.
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`24 Q But generally, I mean there's a -- I mean,
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`25 you folks try to remove heat from LEDs to keep them
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`14
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`PATENT OWNER EXHIBIT 2002
`Page 14
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`ZANE COLEMAN, Ph.D.
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` 1 cooler because they're more efficient and they're
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` 2 longer lived, if you will, if you keep them cooler?
`
` 3 A Those are two reasons for removing heat from
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` 4 an LED.
`
` 5 Q What's another reason for removing heat from
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` 6 an LED?
`
` 7 A Efficiency, lifetime, color temperature.
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` 8 Q What do you mean by color temperature?
`
` 9 A Some LEDs can shift in color over
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`10 temperature.
`
`11 Q Okay. So efficiency, lifetime or life span
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`12 and color temperature. Any other reasons why folks
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`13 try to keep LEDs cool?
`
`14 A Sitting here right now, that's all I can
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`15 recall at this moment.
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`16 Q Are you familiar with the term "chimney
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`17 effect" in the context of heat transfer?
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`18 MS. HARTMAN: Objection, relevance.
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`19 THE WITNESS: Yes.
`
`20 Q What is chimney effect in the context of
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`21 heat transfer?
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`22 MS. HARTMAN: Objection, relevance.
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`23 THE WITNESS: Sitting here right now at this
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`24 time, I can't recall a full definition, but as I
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`25 understand it, it relates to convection of heat from
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`15
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`PATENT OWNER EXHIBIT 2002
`Page 15
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`ZANE COLEMAN, Ph.D.
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` 1 a surface.
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` 2 Q Any other understanding of chimney effect in
`
` 3 the context of heat transfer?
`
` 4 A I believe it relates also to the convection
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` 5 through an opening or channel.
`
` 6 Q Did you consider the chimney effect in any
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` 7 of your analysis in these cases?
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` 8 A No.
`
` 9 Q Do you have an understanding of what a power
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`10 conditioner is in the context of these '968, '844
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`11 and '518 patents?
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`12 A Yes.
`
`13 Q What is it?
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`14 A As generally used in the LSG patents, it's a
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`15 device converting alternating current to DC current
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`16 for driving LEDs.
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`17 Q Would you agree that a power conditioner is
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`18 a heat source?
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`19 A As I understand it, power conditioners do
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`20 generate some heat.
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`21 Q For the record, I'll mark as Exhibit 7 the
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`22 Chou reference.
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`23 (Coleman Exhibit 7 marked for
`
`24 identification.)
`
`25 Q The Chou reference is the 7,670,021 patent.
`
`16
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`PATENT OWNER EXHIBIT 2002
`Page 16
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`ZANE COLEMAN, Ph.D.
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` 1 Dr. Coleman, is it okay if I refer to this as the
`
` 2 Chou reference?
`
` 3 A Yes.
`
` 4 Q Dr. Coleman, you analyzed the Chou reference
`
` 5 in performing your analysis in these cases, correct?
`
` 6 A Yes.
`
` 7 Q You're familiar with the Chou reference?
`
` 8 A Yes.
`
` 9 Q Did you look at the figures of the Chou
`
`10 reference, Figures 1 through 10D in performing your
`
`11 analysis in this case?
`
`12 A I reviewed the entire specification in
`
`13 performing my analysis in this case.
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`14 Q Including the figures?
`
`15 A Yes.
`
`16 Q Chou discloses an LED light bulb, right?
`
`17 A I believe Chou references it as a light
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`18 fixture.
`
`19 Q What are you looking at when you say Chou
`
`20 references a light fixture?
`
`21 A For example, in the summary of invention,
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`22 Chou references light fixture.
`
`23 Q What do you understand light fixture to be
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`24 in the context of the Chou reference? So I'll
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`25 withdraw that question.
`
`17
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`PATENT OWNER EXHIBIT 2002
`Page 17
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`ZANE COLEMAN, Ph.D.
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` 1 It looks to me that they refer to light
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` 2 fixture as fixture 10 in Figure 3. It's kind of the
`
` 3 entire -- I understand that to be the entire LED
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` 4 light bulb plus the recessed can plus the power
`
` 5 conditioner. Is that a fair reading of what Chou
`
` 6 refers to as fixture 10?
`
` 7 A Well, fixture 10 is referenced, for example,
`
` 8 in Figure 2B.
`
` 9 Q Okay. You think what's disclosed in
`
`10 Figure 2B is a light fixture, is that right?
`
`11 A Yes.
`
`12 Q What's disclosed in Figure 1 of the Chou
`
`13 reference? Go ahead. I've been looking for what
`
`14 element 36 is described as and I was going to
`
`15 withdraw the question and say at least I found on
`
`16 bottom of Column 9, element 36 is a light source.
`
`17 Would you agree that Figure 1 of Chou
`
`18 discloses a light source?
`
`19 MS. HARTMAN: Do you have a line number?
`
`20 Q It's way at the bottom, line 60 of Column 9.
`
`21 A I read in Chou where he describes Figure 1
`
`22 as a light-emitting diode LED-based light source and
`
`23 as you referenced as well, he refers to it as a
`
`24 light source.
`
`25 Q If you look at Figures 6A, 6B, 7A and 7B,
`
`18
`
`PATENT OWNER EXHIBIT 2002
`Page 18
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 would you agree those disclose an LED-based light
`
` 2 bulb?
`
` 3 A Sorry. Could you repeat the question,
`
` 4 please?
`
` 5 Q With respect to Figures 6A, 6B, 7A and 7B of
`
` 6 the Chou reference, would you agree that those four
`
` 7 figures disclose a LED-based light bulb?
`
` 8 A Chou references Figures 6A to 6B as a
`
` 9 fixture.
`
`10 Q I understand that, but does it appear to you
`
`11 that Figures 6A and 6B of Chou disclose a specific
`
`12 type of fixture they're disclosing as an LED-based
`
`13 light bulb?
`
`14 A Figures 6A and 6B disclose an LED-based
`
`15 light fixture.
`
`16 Q Is there a difference between an LED-based
`
`17 light fixture and an LED-based light bulb in your
`
`18 understanding?
`
`19 A Yes.
`
`20 Q What is the difference?
`
`21 A An LED bulb is a device that could be
`
`22 installed in a wide range of fixtures generally.
`
`23 And a fixture is an installed light-emitting device.
`
`24 Q Is what's disclosed in Figures 6A, 6B, 7A
`
`25 and 7B installable in a fixture?
`
`19
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`PATENT OWNER EXHIBIT 2002
`Page 19
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 A As Chou states, Figures 6A and 6B are -- can
`
` 2 be -- are fixtures that can be installed in a
`
` 3 recessed can housing.
`
` 4 Q Is the disclosure of Chou for the most part
`
` 5 about recessed light fixtures?
`
` 6 MS. HARTMAN: Objection, form.
`
` 7 THE WITNESS: Could you repeat the question,
`
` 8 please?
`
` 9 Q Is the disclosure in Chou about recessed
`
`10 light fixtures?
`
`11 A Chou discloses LED light fixtures for
`
`12 recessed can houses in his specification.
`
`13 Q Does it disclose any type of light fixtures
`
`14 that are not designed for recessed fixtures, either
`
`15 a recessed can or otherwise?
`
`16 A Sitting here right here and now, I don't
`
`17 recall any additional applications, but I would need
`
`18 to review to be sure that's the case.
`
`19 Q What's a junction box?
`
`20 MS. HARTMAN: Object to form.
`
`21 THE WITNESS: Are you referring to an
`
`22 electrical junction box?
`
`23 Q In the context of the '968, '844 and '518
`
`24 patents, do you have an understanding what a
`
`25 junction box is?
`
`20
`
`PATENT OWNER EXHIBIT 2002
`Page 20
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 A Yes.
`
` 2 Q What is a junction box in the context of the
`
` 3 '968, '844 and '518 patents?
`
` 4 A It is an electrical housing generally
`
` 5 providing connections -- a place for connections.
`
` 6 Q In the context of these three patents, is a
`
` 7 junction box different than a recessed can?
`
` 8 A In the context of these patents, both
`
` 9 electrical junction boxes and recessed can housing
`
`10 house electrical components and components of light
`
`11 fixtures.
`
`12 Q I take it your answer is you're trying to
`
`13 identify the similarities between junction boxes and
`
`14 recessed cans, is that right?
`
`15 A There are similarities between them.
`
`16 Q Are there differences between recessed cans
`
`17 and junction boxes?
`
`18 A Yes.
`
`19 Q What are the differences?
`
`20 A Recessed can housings have a slightly
`
`21 different shape, typically a round opening.
`
`22 Although some junction boxes have round openings.
`
`23 And they are typically deeper than some junction
`
`24 boxes.
`
`25 Q Do you remember in your review of the
`
`21
`
`PATENT OWNER EXHIBIT 2002
`Page 21
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 patents in this case, some of them refer to the
`
` 2 combination of the heat sink and the heat spreader
`
` 3 forming a base?
`
` 4 A Yes.
`
` 5 Q What is a base in the context of the, for
`
` 6 example, '968 patent?
`
` 7 A I don't recall the '968 patent expanding on
`
` 8 the definition of a base.
`
` 9 Q What's your understanding of a base in the
`
`10 context of '968, '844 and '518 patents? So you can
`
`11 look obviously at whatever you'd like to, but
`
`12 there's at least a reference to it here in Column 9.
`
`13 Are you looking at the '968 patent?
`
`14 A Yes.
`
`15 Q At about line 5 of Column 9 of the '968, it
`
`16 says, "In Figure 29 as discussed above, the heat
`
`17 sink is integrally formed with the heat spreader to
`
`18 form a base."
`
`19 Do you see that?
`
`20 A Which line are you referring to?
`
`21 Q I'm in Column 9 of the '968 patent. I was
`
`22 reading from about lines 5 to 8. That's at least
`
`23 one reference to base. There's likely more, but
`
`24 that's the first one I found.
`
`25 A Okay. Your question is?
`
`22
`
`PATENT OWNER EXHIBIT 2002
`Page 22
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 Q What is your understanding of base in the
`
` 2 context of the, for example, '968 patent?
`
` 3 A A base is a component including a heat
`
` 4 spreader and heat sink and possibly other elements.
`
` 5 Q If you turn back to Exhibit 7, which is the
`
` 6 Chou reference, there on Figure 2B, does that
`
` 7 disclose a base?
`
` 8 A In Figure 2B of Chou, trim 12 includes a
`
` 9 heat spreader and a heat sink.
`
`10 Q So are you -- is that your answer, yes, Chou
`
`11 discloses a base?
`
`12 A Chou discloses a heat sink and a heat
`
`13 spreader.
`
`14 Q Does it disclose a base?
`
`15 A Based on the disclosure of the '968 patent,
`
`16 it includes a base.
`
`17 Q Would you take this highlighter and
`
`18 highlight what your opinion is of what the base is
`
`19 in Chou?
`
`20 A The base can include other components.
`
`21 Q Go ahead and highlight what your opinion is
`
`22 of the base in Chou.
`
`23 A The definition of base can include other
`
`24 components, so I could highlight the whole fixture
`
`25 to include other components. It's not necessarily
`
`23
`
`PATENT OWNER EXHIBIT 2002
`Page 23
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 limited to just a heat sink and heat spreader.
`
` 2 Q Okay. Did you form an opinion in this case
`
` 3 that Chou discloses a base in the context of the
`
` 4 '968 patent?
`
` 5 A I formed an opinion that Chou discloses an
`
` 6 integrated heat sink and heat spreader.
`
` 7 Q And it's your opinion that an integrated
`
` 8 heat sink and heat spreader is a base in the context
`
` 9 of the '968 patent?
`
`10 A Could you repeat question, please?
`
`11 Q Is it your opinion that an integrated heat
`
`12 sink and heat spreader in Chou is a base in the
`
`13 context of the '968 patent?
`
`14 A My opinions with respect to the '968 patent
`
`15 were to the claims which refer to a integrally
`
`16 formed heat spreader and heat sink form a base.
`
`17 Q Right. So you're looking at Claim 3 as one
`
`18 of the places -- I think you just read from --
`
`19 A Correct.
`
`20 Q So Claim 3 of the '968 patent requires that
`
`21 the integrally formed heat spreader and heat sink
`
`22 form a base. Do you see that?
`
`23 A Correct.
`
`24 Q Does the Chou reference disclose that
`
`25 limitation?
`
`24
`
`PATENT OWNER EXHIBIT 2002
`Page 24
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 A Yes.
`
` 2 Q Can you identify for me on the Chou
`
` 3 reference with that highlighter what you're relying
`
` 4 on in the disclosure of Chou to meet the limitation
`
` 5 integrally formed heat spreader and heat sink form a
`
` 6 base?
`
` 7 A In the context of Claim 3?
`
` 8 Q Sure.
`
` 9 A Figure 2B is a cross-section, so for
`
`10 example, for me to -- I could highlight the entire
`
`11 trim or I could highlight the -- portions of that as
`
`12 representing the cross-sectional shape.
`
`13 Q Okay.
`
`14 A Do you have a preference?
`
`15 Q No. I just want it to be clear -- I mean,
`
`16 what I would ask you to do is be clear in
`
`17 identifying in Chou what you're relying on, what
`
`18 disclosure in Chou you're relying on to meet the
`
`19 limitation in the '968 patent, the integrally formed
`
`20 heat spreader and heat sink form a base?
`
`21 MS. HARTMAN: Object to form.
`
`22 THE WITNESS: (Indicating).
`
`23 Q Are you done?
`
`24 A It's difficult -- I have highlighted a
`
`25 cross-section portion of the base, not the entire
`
`25
`
`PATENT OWNER EXHIBIT 2002
`Page 25
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 base.
`
` 2 Q Okay. Do you have an understanding of what
`
` 3 the back surface of the base is? Do you have an
`
` 4 opinion that what you identified as the base or what
`
` 5 you're relying on as the base in Chou includes a
`
` 6 back surface?
`
` 7 A There is a back surface of the base of Chou.
`
` 8 Q Can you take my pen and identify, via arrow
`
` 9 or otherwise, what the back surface of the base is
`
`10 in Chou?
`
`11 A The back surface is a -- this is a
`
`12 cross-section of the side and it's not clearly
`
`13 showing the back surface as something that would be
`
`14 readily highlightable.
`
`15 Q I understand maybe it's not readily
`
`16 highlightable, but can you draw an arrow to what you
`
`17 consider the back surface of the base to be in Chou?
`
`18 A (Indicating).
`
`19 Q Could you just identify next to that arrow
`
`20 "back surface"?
`
`21 A (Indicating).
`
`22 Q The claims require that the back side of the
`
`23 base comprise a plurality of heat sink fins and air
`
`24 flow channels.
`
`25 Is it your opinion that the back side of the
`
`26
`
`PATENT OWNER EXHIBIT 2002
`Page 26
`
`
`
`ZANE COLEMAN, Ph.D.
`
` 1 base of Chou discloses a plurality of heat sink
`
` 2 fins?
`
` 3 MS. HARTMAN: Objection, form.
`
` 4 THE WITNESS: Would you repeat the question,
`
` 5 please?
`
` 6 Q Yeah. The '968 patent talks about the back
`
` 7 side of the base including a plurality of heat sink
`
` 8 fins. Does the back side of the base of Chou
`
` 9 disclose a plurality of heat sink fins?
`
`10 MS. HARTMAN: Objection, form.
`
`11 THE WITNESS: In the '968 patent, it states
`
`12 that the heat spreader and heat sink are
`
`13 collectively herein referred to as a base. And as
`
`14 used similarly in other parts of the patent,
`
`15 collectively referred to may include additional
`
`16 components. And the person of ordinary skill in the
`
`17 art would understand that a broadest reasonable
`
`18 construction would be that the base could include
`
`19 portions -- or in this example of Chou, portions of
`
`20 heat sink 14.
`
`21 Q Okay. And so are you relying on Chou or the
`
`22 disclosure in Chou to meet the limitation of the
`
`23 '968 patent that requires wherein a back side of the
`
`24 base comprises a plurality of heat sink fins?
`
`25 MS. HARTMAN: If you're reading from a
`
`27
`
`PATENT OWNER EXHIBIT 2002
`Page 27
`
`
`
`ZANE COLEMAN, Ph
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