Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 1
`
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
`
` 2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` 3 --------------------------------
`
` 4 SEOUL SEMICONDUCTOR CO., LTD.
`
` 5 and SEOUL SEMICONDUCTOR, INC.,
`
` 6 Petitioners, Case No.IPR2018-00333
`
` 7 v. Patent 7,256,486
`
` 8 DOCUMENT SECURITY SYSTEMS, INC.
`
` 9 Patent Owner.
`
` 10
`
` 11 --------------------------------
`
` 12 Washington, D.C.
`
` 13 Friday, September 7, 2018
`
` 14 Deposition of MICHAEL PECHT, PH.D., a witness
`
` 15 herein, called for examination by counsel for the Patent
`
` 16 Owner in the above-entitled matter, pursuant to notice,
`
` 17 the witness being duly sworn by Barbara DeVico, a Notary
`
` 18 Public in and for the District of Columbia, taken at the
`
` 19 offices of HOLLAND & KNIGHT, LLP, 800 17th Street, N.W.,
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` 20 at 9:15, Friday, September 7, 2018, and the proceedings
`
` 21 being taken down by Stenotype by BARBARA De VICO, CRR,
`
` 22 RMR, and transcribed under her direction.
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 1 of 79
`
`
`
`Washington, DC
`
`9/7/2018
`Page 1
`
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
`
` 2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` 3 --------------------------------
`
` 4 SEOUL SEMICONDUCTOR CO., LTD.
`
` 5 and SEOUL SEMICONDUCTOR, INC.,
`
` 6 Petitioners, Case No.IPR2018-00333
`
` 7 v. Patent 7,256,486
`
` 8 DOCUMENT SECURITY SYSTEMS, INC.
`
` 9 Patent Owner.
`
` 10
`
` 11 --------------------------------
`
` 12 Washington, D.C.
`
` 13 Friday, September 7, 2018
`
` 14 Deposition of MICHAEL PECHT, PH.D., a witness
`
` 15 herein, called for examination by counsel for the Patent
`
` 16 Owner in the above-entitled matter, pursuant to notice,
`
` 17 the witness being duly sworn by Barbara DeVico, a Notary
`
` 18 Public in and for the District of Columbia, taken at the
`
` 19 offices of HOLLAND & KNIGHT, LLP, 800 17th Street, N.W.,
`
` 20 at 9:15, Friday, September 7, 2018, and the proceedings
`
` 21 being taken down by Stenotype by BARBARA De VICO, CRR,
`
` 22 RMR, and transcribed under her direction.
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 1 of 79
`
`
`
`Michael Pecht, Ph.D.
`
` 1 APPEARANCES:
`
` 2
`
`Washington, DC
`
`9/7/2018
`Page 2
`
` 3 On Behalf of the Petitioners
`
` 4 MICHAEL EISENBERG, ESQUIRE
`
` 5 HOLLAND & KNIGHT, LLP
`
` 6 31 West 52nd Street
`
` 7 New York, New York 10019
`
` 8 (212)513-3529
`
` 9 michael.eisenberg@hklaw.com
`
` 10
`
` 11 On behalf of the Patent Owner
`
` 12 WAYNE HELGE, ESQUIRE
`
` 13 DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
`
` 14 8300 Greensboro Drive, Suite 500
`
` 15 McLean, VA 22102
`
` 16 (571)765-7708
`
` 17 whelge@dbjg.com
`
` 18
`
` 19
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` 20
`
` 21
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` 22
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 2 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 3
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` 1 TABLE OF CONTENTS
`
` 2 WITNESSES
`
` 3 WITNESS PAGE
`
` 4 MICHAEL GERARD PECHT
`
` 5 BY MR. HELGE 4
`
` 6
`
` 7
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` 8
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` 9
`
` 10 EXHIBITS
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` 11
`
` 12 No Exhibits Marked
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` 13 (Previously marked exhibits won't be attached.)
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` 14
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` 15
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` 16
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` 17
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` 18
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` 19
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` 20
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` 21
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` 22
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 3 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 4
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` 1 P R O C E E D I N G S
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` 2 ***********************
`
` 3 MICHAEL GERARD PECHT,
`
` 4 having been called as a witness on behalf of the
`
` 5 Petitioner and having been first duly sworn, was
`
` 6 examined and testified as follows:
`
` 7 EXAMINATION BY
`
` 8 MR. HELGE:
`
` 9 Q Good morning, Dr. Pecht.
`
` 10 A Good morning.
`
` 11 Q Doctor, LED stands for light-emitting
`
` 12 diode; correct?
`
` 13 A Correct.
`
` 14 Q And a light-emitting diode is a
`
` 15 semiconductor device; correct?
`
` 16 A Correct.
`
` 17 Q You can also refer to an LED as a
`
` 18 semiconductor die or chip, right?
`
` 19 MR. EISENBERG: Object to the form.
`
` 20 THE WITNESS: LED can be made from
`
` 21 semiconductor materials and put in the form of a
`
` 22 semiconductor chip or die.
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 4 of 79
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`Michael Pecht, Ph.D.
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` 1 BY MR. HELGE:
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`Washington, DC
`
`9/7/2018
`Page 5
`
` 2 Q The term "light emitting" is clear. What
`
` 3 does the diode implicate in the term "LED" or
`
` 4 "light-emitting diode"?
`
` 5 MR. EISENBERG: Objection to the form.
`
` 6 THE WITNESS: Well, the diode allows
`
` 7 the flow of current in a certain manner. So like you
`
` 8 can say like a resistor allows the flow of current, but
`
` 9 it creates a resistance with that. A capacitor allows
`
` 10 the flow of current under changing conditions, and diode
`
` 11 allows the flow of current under a particular, for a
`
` 12 particular voltage value.
`
` 13 So for some voltage, you might see that
`
` 14 there's no current flow, and then it will increase, for
`
` 15 example. So it will have a certain characteristic of
`
` 16 voltage.
`
` 17 Q And a light-emitting diode has to be
`
` 18 powered in order to emit light, correct?
`
` 19 A Correct.
`
` 20 Q How is power usually provided to a
`
` 21 light-emitting diode?
`
` 22 MR. EISENBERG: Objection to the form.
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`1-800-FOR-DEPO
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 5 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 6
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` 1 THE WITNESS: To the anode and the
`
` 2 cathode of the device.
`
` 3 BY MR. HELGE:
`
` 4 Q What do you mean, "device"?
`
` 5 A The LED. So it has an anode and cathode.
`
` 6 In layman's terms we just say power and ground. So
`
` 7 there would be connections to that, to the power and
`
` 8 ground, to the terminals or contacts of the LED.
`
` 9 Q And that power is usually provided to the
`
` 10 LED using a package format, correct?
`
` 11 MR. EISENBERG: Objection to the form.
`
` 12 Q Let me ask the question a different way.
`
` 13 What's the point of attaching an LED chip to a package?
`
` 14 A There's many. So the package serves to
`
` 15 protect the die. If there's wire bonding, to protect
`
` 16 the wire bonds, because the wire bonds are quite
`
` 17 fragile. To help reflect more light. To help protect
`
` 18 against environmental concerns, vibrations, perhaps, or
`
` 19 shock loading or humidity.
`
` 20 A variety of -- and then the package also
`
` 21 serves, because the -- it serves as a connection to a
`
` 22 circuit board often. Because the LED die itself, the
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 6 of 79
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`
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 7
`
` 1 semiconductor device itself, is very, very small and
`
` 2 it's not easy to handle. You put it into a package
`
` 3 because the package, even though the package is also
`
` 4 very small, it's easier to handle without damaging it
`
` 5 than an individual LED. So there's many reasons.
`
` 6 Q Dr. Pecht, a moment ago I believe you
`
` 7 said that the LED chip is very, very small.
`
` 8 A Is generally small. Is generally very
`
` 9 small, yes.
`
` 10 Q That LED chip when a method of connection
`
` 11 uses a wire bond, that wire bond is even smaller than
`
` 12 the LED chip; correct?
`
` 13 A What do you mean by the wire bond? The
`
` 14 wire?
`
` 15 Q That's right.
`
` 16 A The diameter of the wire is typically
`
` 17 very small. I think -- anyway, it's thinner than the
`
` 18 human hair diameter. But the length can be, again,
`
` 19 depending on the package, can be longer. It would
`
` 20 generally be many, many, probably hundreds of times that
`
` 21 of the diameter.
`
` 22 Q That makes sense. So let me ask you
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`1-800-FOR-DEPO
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`Patent Owner's Exhibit 2003
`Page 7 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 8
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` 1 this: In a package in which an LED chip is to be wire
`
` 2 bonded to a terminal or contact, what sorts of
`
` 3 procedures are used to assemble the wire bonds in
`
` 4 exactly the right locations in order to ensure that the
`
` 5 top of the LED chip or whatever part of the LED chip is
`
` 6 as a contact is secured to one end of that wire bond?
`
` 7 MR. EISENBERG: Objection to the form.
`
` 8 THE WITNESS: So there's automated
`
` 9 equipment for manufacturing wire bonding equipment. And
`
` 10 so it's typically an optical, optical equipment. So --
`
` 11 whereas the pad or the contact or electrode or the
`
` 12 metallization on the LED, and then it forms the contact
`
` 13 on that side, and then it lets out the wire, so to
`
` 14 speak, and forms what we call a loop and connects it to
`
` 15 the substrate pad or contact pad on the substrate and
`
` 16 forms a bond, another bond there.
`
` 17 BY MR. HELGE:
`
` 18 Q Okay. And that's wire bond equipment you
`
` 19 said?
`
` 20 A There would be wire bond. Semi-automated
`
` 21 and automated wire bonding equipment that does that.
`
` 22 Q And what is the typical dimension of the
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 8 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 9
`
` 1 pad or contact or electrode on top of an LED chip that
`
` 2 receives the wire bond?
`
` 3 MR. EISENBERG: Objection to the form.
`
` 4 THE WITNESS: It could be -- it's
`
` 5 typically made not too big. I'm trying to think of it
`
` 6 in terms of the size, the diameter of the wire. It
`
` 7 might be many times the size of the wire. But I would
`
` 8 say that there's no, necessarily any restriction. I
`
` 9 mean, there might be a reason that -- so there's things
`
` 10 called ball bonds, and ball bonds maybe take up less
`
` 11 space. There could be stitch bonds that take up more
`
` 12 space, so you want the contact pad bond or the
`
` 13 metallization on the electrode -- on the LED to be
`
` 14 bigger. So it can vary.
`
` 15 BY MR. HELGE:
`
` 16 Q So the wire bond once it's been installed
`
` 17 between the LED chip and the substrate pad or contact
`
` 18 pad, you would agree that that wire bond is fragile; is
`
` 19 that right?
`
` 20 A Yes, it's usually considered fragile.
`
` 21 Q And in order to protect the LED chip and
`
` 22 the wire bond, an encapsulant is usually applied on top
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 9 of 79
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`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 10
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` 1 of the LED chip with the wire bond; correct?
`
` 2 A Correct.
`
` 3 Q How is the wire bond protected from
`
` 4 damage when the encapsulant is being installed?
`
` 5 MR. EISENBERG: Objection to the form.
`
` 6 THE WITNESS: When the encapsulant is
`
` 7 being applied?
`
` 8 BY MR. HELGE:
`
` 9 Q Applied, yes.
`
` 10 A So it's a strange question. It's not
`
` 11 that fragile then, okay. So it's fragile, but it's not
`
` 12 fragile -- the molding process -- well, first of all,
`
` 13 there's a couple molding processes. So you can put --
`
` 14 you can use a syringe-type molding process in which a
`
` 15 liquid is put kind of syringed on to cover.
`
` 16 You can use the transfer molding process, and
`
` 17 there the pressure is quite a bit higher. I mean, I
`
` 18 would say probably significantly higher. And people
`
` 19 worry about things like they call wire sweep where one
`
` 20 wire might move into another wire.
`
` 21 But for an LED, typically you only have one
`
` 22 wire. So even if you have sweep, it's not a problem.
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 10 of 79
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`Michael Pecht, Ph.D.
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`Washington, DC
`
`9/7/2018
`Page 11
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` 1 Usually, I mean, unless you have a bad connection you
`
` 2 probably, the transfer molding process wouldn't cause a
`
` 3 problem with the wire.
`
` 4 The problem with the wire would occur if
`
` 5 somebody is doing something by hand and touches the
`
` 6 wire. That might be a problem.
`
` 7 Q You'd agree that if a wire bond is
`
` 8 fractured or rendered discontinuous in any way, that LED
`
` 9 chip is ineffective; right?
`
` 10 A Correct. If that was connected to the
`
` 11 power or ground, right.
`
` 12 Q Doctor, have you heard the term "top
`
` 13 emitting" with respect to an LED?
`
` 14 A Well, you can have light that's emitted
`
` 15 from the different surfaces of the LED, and some could
`
` 16 come out the top.
`
` 17 Q Some light?
`
` 18 A Some light can come out of the top, yes.
`
` 19 Q Are you familiar with the term "top
`
` 20 emitting LED"?
`
` 21 A I don't think it's a normal term of art.
`
` 22 Q How about bottom emitting? Is that a
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 11 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 12
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` 1 term of art in the LED space?
`
` 2 A Even though I don't like to say it,
`
` 3 whether either one of those is a term of art or not, it
`
` 4 might be used as a term of art by one company. It
`
` 5 depends on the company. It depends on the company, the
`
` 6 country, these kind of things, in terms of these terms.
`
` 7 So what I meant was it's not necessarily a term
`
` 8 of art that I'm normally accustomed to, but I understand
`
` 9 what you meant, probably what you meant when you said
`
` 10 that.
`
` 11 Q When an LED chip is connected to a
`
` 12 package and you have an LED device, is it common that
`
` 13 the preferred direction of the emitted light is away
`
` 14 from the package?
`
` 15 MR. EISENBERG: Objection to the form.
`
` 16 THE WITNESS: I'm worried that your
`
` 17 question is too trivial. So I'm not sure if I
`
` 18 understand it exactly. It's not -- the light is not
`
` 19 going to go inside the package and be contained inside
`
` 20 the package. The purpose is to light something up. So
`
` 21 the light will go outside, it's supposed to go outside
`
` 22 the package. Whether it's to light a lightbulb or
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 12 of 79
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`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 13
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` 1 display or something, the purpose is for the light to in
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` 2 effect leave the package.
`
` 3 BY MR. HELGE:
`
` 4 Q I'm thinking more about the direction of
`
` 5 the light and the direction of the emitted light versus
`
` 6 the location of the package. And so if you have -- in
`
` 7 some of these examples we'll talk about in a little bit
`
` 8 here, you may have an LED chip sitting on top of a
`
` 9 substrate with contact pads, and that substrate may be
`
` 10 then connected to a printed circuit board. And in that
`
` 11 scenario, the intended direction of the emitted light is
`
` 12 away from the printed circuit board. So in the drawings
`
` 13 that we're seeing it would be up.
`
` 14 Do you agree with that?
`
` 15 MR. EISENBERG: Objection to the form.
`
` 16 THE WITNESS: I would agree that would
`
` 17 be away from the printed circuit board. It could be
`
` 18 depending on your, in principle depending on the
`
` 19 orientation of the package and your encapsulant shape,
`
` 20 it could be spread out parallel to the surface of the
`
` 21 board as well. But it would be external to the board,
`
` 22 yeah.
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`1-800-FOR-DEPO
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`Alderson Court Reporting
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`www.AldersonReporting.com
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`Patent Owner's Exhibit 2003
`Page 13 of 79
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`Michael Pecht, Ph.D.
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` 1 BY MR. HELGE:
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`Washington, DC
`
`9/7/2018
`Page 14
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` 2 Q Doctor, I'm going to hand you a copy of
`
` 3 what's been already submitted into this case as the Rohm
`
` 4 patent. Doctor, this has been labeled as Exhibit 1008
`
` 5 in this case. You'll see that at the bottom.
`
` 6 Doctor, if you can turn if you can to
`
` 7 Paragraph 16 of the translation.
`
` 8 A (Witness complies with request.)
`
` 9 Q Do you see at the very beginning of
`
` 10 Paragraph 16 Rohm states, "A top surface light
`
` 11 emitting-type LED chip 30 is placed on and die bonded to
`
` 12 the top surface of the die bonding electrode"?
`
` 13 Do you see that?
`
` 14 A Yes.
`
` 15 Q What does Rohm mean by a top surface
`
` 16 light emitting-type LED chip?
`
` 17 MR. EISENBERG: Objection to the form.
`
` 18 THE WITNESS: You can have light that's
`
` 19 emitted from the top.
`
` 20 BY MR. HELGE:
`
` 21 Q Your answer is that you can have light
`
` 22 that is emitted from the top?
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`Patent Owner's Exhibit 2003
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`Michael Pecht, Ph.D.
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`Washington, DC
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`9/7/2018
`Page 15
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` 1 A Right.
`
` 2 Q Let me ask you this: The top of what?
`
` 3 A The top of the die.
`
` 4 Q So by stating a top surface light
`
` 5 emitting-type LED chip here in Paragraph 16, do you
`
` 6 agree that Rohm is saying that you would have light
`
` 7 emitting from the top surface of the LED chip 30?
`
` 8 A You can. It might also be illuminating
`
` 9 from the sides as well.
`
` 10 Q Does it say side surface light emitting
`
` 11 type?
`
` 12 A No. But remember, I said that the light
`
` 13 emits actually from all directions.
`
` 14 Q Okay.
`
` 15 A And I think one of the purposes here was
`
` 16 to say that can they put on -- let me just look one more
`
` 17 time. I haven't looked at this for a while.
`
` 18 (Pause)
`
` 19 A Okay. Go ahead. I just wanted to make
`
` 20 sure I understood what we were talking about precisely.
`
` 21 Q Doctor, you said you spent quite a while
`
` 22 looking at Rohm in preparation for this deposition; is
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`Patent Owner's Exhibit 2003
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`Michael Pecht, Ph.D.
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` 1 that right?
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`Washington, DC
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`9/7/2018
`Page 16
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` 2 A No. I don't think I said that.
`
` 3 Q I'm sorry. You said, "I haven't looked
`
` 4 at this for a while," right?
`
` 5 A No.
`
` 6 Q Let me ask you this: What did you do to
`
` 7 prepare for this deposition?
`
` 8 A I looked at the patent and my
`
` 9 declaration, predominantly.
`
` 10 Q By "patent," do you mean the '486 patent?
`
` 11 A Yes, that's correct.
`
` 12 MR. HELGE: Can we go off the record.
`
` 13 (Discussion held off the
`
` 14 record.)
`
` 15 BY MR. HELGE:
`
` 16 Q Doctor, let's see here. If you look at
`
` 17 Rohm's figure 1.
`
` 18 A (Witness complies with request.)
`
` 19 Q This is a little blurry, so I apologize.
`
` 20 Do you see --
`
` 21 MR. EISENBERG: I think we probably
`
` 22 blew it up in the petition. Maybe it would be a little
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`Patent Owner's Exhibit 2003
`Page 16 of 79
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`Michael Pecht, Ph.D.
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`Washington, DC
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`9/7/2018
`Page 17
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` 1 easier to see. We may not have. I usually do that.
`
` 2 You did the double page thing.
`
` 3 MR. HELGE: It's a little clearer.
`
` 4 BY MR. HELGE:
`
` 5 Q Doctor, I'm going to hand you a copy of
`
` 6 the petition, and the relevant parts of Rohm that we're
`
` 7 going to be talking about are here on pages 20 through
`
` 8 22.
`
` 9 Do you see LED chip 30 in this figure?
`
` 10 A Yes.
`
` 11 Q What is element 30a? And Paragraph 16
`
` 12 will have the answer if you don't know.
`
` 13 A I didn't follow what you were saying.
`
` 14 30a of 30?
`
` 15 Q 30a. Do you see element 30a in that
`
` 16 drawing?
`
` 17 A Yes.
`
` 18 Q What is element 30a?
`
` 19 A I thought you were pointing me to
`
` 20 Paragraph 30.
`
` 21 MR. EISENBERG: I think he pointed you
`
` 22 to Paragraph 16 of the translation of Rohm.
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`Patent Owner's Exhibit 2003
`Page 17 of 79
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`Michael Pecht, Ph.D.
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`Washington, DC
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`9/7/2018
`Page 18
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` 1 THE WITNESS: Okay. I'm sorry, I
`
` 2 didn't follow that.
`
` 3 So they're calling it a wire bonding --
`
` 4 in addition, a front surface electrode 30a of the LED
`
` 5 chip. And then they have a wire bonding electrode 20
`
` 6 that's wire bonded with the wire of 32.
`
` 7 BY MR. HELGE:
`
` 8 Q Okay, Doctor. So you agree that 30a is a
`
` 9 front surface electrode of the LED chip, correct?
`
` 10 A Yes. It's like a contact or electrode.
`
` 11 Q One thing that we hadn't gone over
`
` 12 yesterday and we have to be careful that we don't speak
`
` 13 over each other. To the extent that I've done it, I
`
` 14 apologize.
`
` 15 MR. EISENBERG: And just in case I'll
`
` 16 give the same sort of instruction. Make sure that I
`
` 17 have time between his question and your answer so that I
`
` 18 can object, if necessary. Hopefully infrequently.
`
` 19 Q Doctor, would you agree that front
`
` 20 surface electrode 30a on LED chip 30 in Rohm occupies a
`
` 21 relatively small portion of that upper surface of the
`
` 22 LED chip 30?
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 18 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 19
`
` 1 MR. EISENBERG: Objection to the form.
`
` 2 THE WITNESS: The picture here makes it
`
` 3 look like it's smaller than the top surface, but it
`
` 4 could be any size, as I mentioned, according to how it
`
` 5 might be wire bonded or how thick they might want to
`
` 6 make the wire, how much power.
`
` 7 So one of the things is that for, as
`
` 8 you have more power, you have more current. And if you
`
` 9 have more current, then you need a thicker wire. So
`
` 10 depending on your power requirements and things of that
`
` 11 nature, those, that metallization can be bigger or
`
` 12 smaller.
`
` 13 BY MR. HELGE:
`
` 14 Q Doctor, you agree that an LED chip
`
` 15 includes a light emitting layer; correct?
`
` 16 MR. EISENBERG: Objection to the form.
`
` 17 THE WITNESS: Where are you? Are you
`
` 18 reading this from my declaration?
`
` 19 BY MR. HELGE:
`
` 20 Q I'm just asking you a question.
`
` 21 A What is the question again, I'm sorry.
`
` 22 Q Do you agree that an LED chip includes a
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 19 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 20
`
` 1 light emitting layer?
`
` 2 MR. EISENBERG: Same objection.
`
` 3 THE WITNESS: I'm not sure what you
`
` 4 mean by "layer" there. I mean, the structure can be
`
` 5 layered and there could be light emitted from many
`
` 6 different layers.
`
` 7 BY MR. HELGE:
`
` 8 Q Doctor, in the LED field, what is meant
`
` 9 by an active layer?
`
` 10 A I think where the photons are generated.
`
` 11 Q And are those photons emitted in the form
`
` 12 of light?
`
` 13 A Yes, photons is light, yes.
`
` 14 Q All right, Doctor. You agree that an LED
`
` 15 chip would include an active layer, correct?
`
` 16 A Yes.
`
` 17 Q Would you agree that the active layer of
`
` 18 the LED chip is a layer that emits the photons?
`
` 19 A Yes.
`
` 20 Q In LED chip 30 of Rohm, do you know --
`
` 21 A It could emit the photons throughout the
`
` 22 LED.
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 20 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 21
`
` 1 Q What do you mean, "throughout"?
`
` 2 A Through any optically -- any place where,
`
` 3 any region in which a photon could pass through, it
`
` 4 would emit through. Even though it was generated --
`
` 5 clearly, for example, the encapsulant, the photons can
`
` 6 go through the encapsulant. It can go through a variety
`
` 7 of materials. And so depending on the structure of the
`
` 8 LED, it can, even though it's generated in the active
`
` 9 region, it moves throughout, can move throughout the LED
`
` 10 itself, depending on the structure of the LED.
`
` 11 Q Looking at Rohm's LED chip 30, do photons
`
` 12 pass from an active layer through top surface -- excuse
`
` 13 me, front surface electrode 30a?
`
` 14 MR. EISENBERG: Objection to the form.
`
` 15 THE WITNESS: No, they would be --
`
` 16 well, they probably would not pass through there. They
`
` 17 would be reflected from 30a. And that's why you have,
`
` 18 sometimes you have a coating on the surface, so it would
`
` 19 be reflected back.
`
` 20 So in this case, the back surface is
`
` 21 metallized, you would have reflections from the back
`
` 22 surface upwards, so to speak, and light would be emitted
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 21 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 22
`
` 1 from throughout the sides and the top, depending on,
`
` 2 again, on the size of the metallization on the top.
`
` 3 BY MR. HELGE:
`
` 4 Q Do you agree that if front surface
`
` 5 electrode 30a were increased in size to occupy the
`
` 6 entire upper surface of LED chip 30, then no light or
`
` 7 photons would pass out from that upper surface?
`
` 8 A Yeah. Most likely. Probably depends on
`
` 9 the amount of metallization to some extent.
`
` 10 Q So you agree that the amount --
`
` 11 A Let me say it this way: You would have
`
` 12 an increasing amount of reflection by the metallization.
`
` 13 Q So you agree you would have more
`
` 14 reflection of photons as the size of front surface
`
` 15 electrode 30a increased; is that right?
`
` 16 A Right.
`
` 17 Q Doctor, in your experience -- excuse me.
`
` 18 Doctor, based on your experience do you have an opinion
`
` 19 whether LED chip 30 in Rohm would include a substrate?
`
` 20 A What do you mean by "substrate"?
`
` 21 Q Is there a common definition for
`
` 22 substrate in the LED field?
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 22 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 23
`
` 1 A I doubt it. Just because different
`
` 2 companies use different languages and stuff. So there
`
` 3 could be and there might not be. I think it's just very
`
` 4 diverse.
`
` 5 Q Does Rohm disclose whether LED chip 30
`
` 6 includes a substrate?
`
` 7 A Well, I'm just looking right in front of
`
` 8 me on page 20. It says it discloses a -- well, let me
`
` 9 look. That might be a different one.
`
` 10 Q Right. For clarification I'm not
`
` 11 asking --
`
` 12 A Many substrates here. Many potential
`
` 13 substrates here.
`
` 14 Q Okay.
`
` 15 A You're talking about whether the LED
`
` 16 device itself --
`
` 17 Q Yes.
`
` 18 A -- was, for example, formed on a
`
` 19 substrate?
`
` 20 Q I don't want to confuse the question.
`
` 21 I'm not asking whether LED chip 30 was formed on a
`
` 22 substrate. I'm just simply asking you whether in your
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 23 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 24
`
` 1 opinion you believe LED chip 30 includes a substrate.
`
` 2 MR. EISENBERG: Objection.
`
` 3 THE WITNESS: I guess that would -- the
`
` 4 first thing I would do to answer that question is look
`
` 5 at Rohm to see if they used the word "substrate." Do
`
` 6 you want me to do that?
`
` 7 BY MR. HELGE:
`
` 8 Q Have you done it in the past?
`
` 9 A No, I have not.
`
` 10 Q So you would have to read through Rohm
`
` 11 entirely to know whether LED chip 30 includes a
`
` 12 substrate?
`
` 13 A Per their definition of substrate, yes.
`
` 14 Q But you agree that LED chip 30 of Rohm
`
` 15 includes an active layer, correct?
`
` 16 A The active layer in the sense that we
`
` 17 define that there's going to be some region that
`
` 18 generates photons, yeah. Is there a region in LED
`
` 19 devices that generates photons, the answer is yes.
`
` 20 Q Doctor, do you see die bonding electrode
`
` 21 80 -- excuse me. Do you see die bonding electrode 18 in
`
` 22 Rohm's figure 1?
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 24 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 25
`
` 1 MR. EISENBERG: Again, if it's helpful,
`
` 2 there might be a clearer version.
`
` 3 THE WITNESS: This one?
`
` 4 BY MR. HELGE:
`
` 5 Q Yes, sir. The number is 18.
`
` 6 MR. EISENBERG: I have a full-sized
`
` 7 version of the petition if you just want me to --
`
` 8 MR. HELGE: I'd be happy.
`
` 9 THE WITNESS: Thank you, because my
`
` 10 eyes are really bad. So we're looking at --
`
` 11 BY MR. HELGE:
`
` 12 Q Figure 1.
`
` 13 A Okay. I've got it. I'm at 18.
`
` 14 Q Okay. Doctor, so that is referred to in
`
` 15 Rohm as die bonding electrode 18. Do you see that
`
` 16 electrode there?
`
` 17 MR. EISENBERG: Objection to the form.
`
` 18 THE WITNESS: Yes.
`
` 19 BY MR. HELGE:
`
` 20 Q In your opinion what type of material is
`
` 21 used to form die bonding electrode 18?
`
` 22 A Oftentimes it's some kind of metal. I'd
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 25 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 26
`
` 1 have to go through Rohm to see what he specifically,
`
` 2 what they specifically used.
`
` 3 Q You agree -- excuse me. I would say it's
`
` 4 your opinion that metallization layers are frequently
`
` 5 and commonly used to provide electrodes to the types of
`
` 6 components disclosed by Rohm; correct?
`
` 7 A I would agree.
`
` 8 Q So you agree that even if Rohm does not
`
` 9 disclose the material being used to form electrode 18,
`
` 10 it's your opinion that the electrode would most likely
`
` 11 be a metallization; correct?
`
` 12 A Yes.
`
` 13 Q Would Rohm's die bonding electrode 18 be
`
` 14 reflective?
`
` 15 A It could be, yes, yes. Absolutely.
`
` 16 Q Doctor, in an LED chip with multiple
`
` 17 layers, what happens to photons that pass across the
`
` 18 boundary from one layer to the next?
`
` 19 MR. EISENBERG: Objection to the form.
`
` 20 THE WITNESS: It's quite complex. I
`
` 21 think it really depends on the materials, yeah. It
`
` 22 could be recombinations. There could be some
`
`1-800-FOR-DEPO
`
`Alderson Court Reporting
`
`www.AldersonReporting.com
`
`Patent Owner's Exhibit 2003
`Page 26 of 79
`
`
`
`Michael Pecht, Ph.D.
`
`Washington, DC
`
`9/7/2018
`Page 27
`
` 1 transmissions, some reflections, depending on all the
`
` 2 materials.
`
` 3 BY MR. HELGE:
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