Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`APPLE, INC.,
`Petitioner,
`v.
`UUSI,LLC, d/b/a NARTRON,
`Patent Owner.
`__________________
`Case IPR2019-00358; IPR2019-00359
`Patent No. 5,796,183
`__________________
`
`Expert Deposition of
`PHILLIP D. WRIGHT, Ph.D.
`Arlington, Virginia
`Thursday, September 26, 2019
`9:02 a.m.
`
`Job No: 47624
`
`Reported by: Donna A. Peterson, Notary Public
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`Wright, Ph.D., Phillip D.
`September 26, 2019
`
`1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`APPLE, INC.,
`Petitioner,
`v.
`UUSI,LLC, d/b/a NARTRON,
`Patent Owner.
`__________________
`Case IPR2019-00358; IPR2019-00359
`Patent No. 5,796,183
`__________________
`
`Expert Deposition of
`PHILLIP D. WRIGHT, Ph.D.
`Arlington, Virginia
`Thursday, September 26, 2019
`9:02 a.m.
`
`Job No: 47624
`
`Reported by: Donna A. Peterson, Notary Public
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
`
`2
`
` The Expert Deposition of PHILLIP D.
`WRIGHT, Ph.D., taken at the law offices of:
`
` NIXON & VANDERHYE, P.C.
` Suite 1100
` 901 North Glebe Road
` Arlington, Virginia 22203
`
` Pursuant to Notice, before Donna A.
`Peterson, Notary Public in and for the Commonwealth
`of Virginia.
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
`
`3
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` A P P E A R A N C E S
`
` ON BEHALF OF PETITIONER:
` DANIEL D. SMITH, ATTORNEY at LAW
` FISH & RICHARDSON, P.C.
` 3200 RBC Plaza
` 60 South Sixth Street
` Minneapolis, Minnesota 55402
` Telephone: (612) 335-5070
` dsmith@fr.com
`
` RYAN CHOWDHURY, J.D.
` FISH & RICHARDSON, P.C.
` 1000 Maine Avenue, Southwest
` Washington, D.C. 20024
` Telephone: (202) 783-5070
` rchowdhury@fr.com
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
`
` A P P E A R A N C E S C O N T I N U E D
`
`4
`
`ON BEHALF OF PATENT OWNER:
` LAWRENCE M. HADLEY, ATTORNEY at LAW
` GLASER, WEIL, FINK, HOWARD,
` AVCHEN & SHAPIRO, LLP
` 19th Floor
` 10250 Constellation Boulevard
` Los Angeles, California 90067
` Telephone: (310) 553-3000
` LHadley@Glaserweil.com
`
` ON BEHALF OF PATENT OWNER:
` JONATHAN A. ROBERTS, ATTORNEY at LAW
` NIXON & VANDERHYE, P.C.
` Suite 1100
` 901 North Glebe Road
` Arlington, Virginia 22203
` Telephone: (703) 816-4414
` JR@nixonvan.com
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` C O N T E N T S
`EXAMINATION OF PHILLIP D. WRIGHT, Ph.D. PAGE
` By Mr. Hadley 7
` E X H I B I T S
` (Exhibits attached to the transcript.)
`EXHIBIT DESCRIPTION PAGE
`Wright 1 Petition For Inter Partes Review 11
` Of United States Patent No.
` 5,796,183 Pursuant To 35 U.S.C.
` §§ 311-319, 37 C.F.R. §42
`Wright 2 Declaration Of Dr. Phillip D. 11
` Wright
` APPLE 1003
`Wright 3 Petition For Inter Partes Review 15
` Of United States Patent No.
` 5,796,183 Pursuant to 35 U.S.C.
` §§ 311-319, 37 C.F.R. §42
`Wright 4 Declaration Of Dr. Phillip D. 15
` Wright
` APPLE 1003
`
`
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
`
`6
`
` E X H I B I T S C O N T I N U E D
`EXHIBIT DESCRIPTION PAGE
`Wright 5 U.S. Patent And Trademark Office, 264
` Before The Patent Trial And Appeal
` Board, Case IPR2019-00358,
` Patent No. 5,796,183,
` Decision Granting Institution of
` Inter Partes Review, 35 U.S.C. §314
`
` PREVIOUSLY MARKED EXHIBITS
`APPLE 1001 United States Patent No. 34
` 5,796,183, Hourmand
`APPLE 1005 United States Patent No. 174
` 4,561,002, Chiu
`APPLE 1014 United States Patent No. 175
` 4,418,333, Schwarzbach et al.
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` P R O C E E D I N G S
`Thereupon,
` PHILLIP D. WRIGHT, Ph.D.,
`was called as a witness by counsel for Patent Owner,
`and having been duly sworn by the Notary Public, was
`examined and testified as follows:
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`BY MR. HADLEY:
` Q. Good morning.
` Can you state your name.
` A. Phillip D. Wright.
` Q. And you hold a doctorate degree, is that
`correct?
` A. Correct.
` Q. In what?
` A. My Ph.D. is in electrical engineering.
` Q. From where?
` A. University of Illinois Urbana-Champaign.
` Q. And what year?
` A. The Ph.D. was, I believe, 1977.
` Q. And is it correct that you have provided a
`number of declarations in connection with various
`
`202-220-4158
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`Henderson Legal Services, Inc.
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`inter partes review regarding a patent with the title
`Capacitive Responsive Electronic Switching Circuit?
` A. Yes.
` Q. And do you understand that the United
`States Patent and Trademark -- I'm sorry, the Patent
`Trial and Appellate Board at the U.S. PTO has
`instituted inter partes review on two of those
`petitions involving that patent?
` A. Yes.
` Q. And the two petitions that have been
`instituted are what we -- at least I call the '358
`petition and the '359 petition.
` Is that your understanding, as well?
` A. Yeah, it's those same numbers.
` Q. Is it okay if we refer to those IPR's as
`the 358 and 359?
` A. I think so. It's confusing sometimes, but
`358, 359, we'll try to use.
` Q. All right. And your declaration provides
`various opinions regarding the validity of that
`patent, is that correct?
` MR. SMITH: Objection, form.
`
`202-220-4158
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`Henderson Legal Services, Inc.
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` MR. HADLEY: Let me, let me restate.
`BY MR. HADLEY:
` Q. Is it correct that your declarations in
`the 358 and the 359 IPR's express opinions regarding
`the validity of U.S. Patent 5,796,183, which has the
`title Capacitive Responsive Electronic Switching
`Circuit?
` MR. SMITH: Same objection.
` MR. HADLEY: You can answer.
` THE WITNESS: I don't think it's the
`validity, it's the obviousness of the claims of the
`'183 patent.
`BY MR. HADLEY:
` Q. Is it your understanding that there's a
`difference between obviousness and validity?
` MR. SMITH: Objection, form.
` THE WITNESS: Yes.
`BY MR. HADLEY:
` Q. What is that difference?
` MR. SMITH: Same objection.
` THE WITNESS: Well, I'm not an attorney,
`I'm an engineer, so --
`
`202-220-4158
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`BY MR. HADLEY:
` Q. What is your lay engineering understanding
`of the difference between obviousness and validity?
` A. Validity is whether or not the claims are
`correct, valid, meaningful; as opposed to obvious
`being obvious to a person of ordinary skill in the
`art based upon his knowledge of the field, the prior
`art and in light of all of the prior art that
`preceded the critical date of the, for example, the
`'183 patent.
` Q. Do you know whether obviousness has
`anything to do with validity?
` MR. SMITH: Objection, form.
` THE WITNESS: Again, I'm not an attorney.
`Obviousness -- I've always thought of them as -- as
`kind of different criteria.
`BY MR. HADLEY:
` Q. Do you have an opinion as to whether the
`challenged claims in IPR's 358 and 359 in the '183
`patent are invalid?
` MR. SMITH: Objection, form.
` THE WITNESS: I wasn't asked to opine on
`
`202-220-4158
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`whether or not the claims were valid, so I really
`haven't processed that thought at all.
` MR. HADLEY: Let me go ahead and get a
`couple of exhibits marked.
` Let's go ahead and mark this as Wright 2.
` (Wright deposition Exhibits Numbers 1 and
`2 were marked for identification and attached to the
`transcript.)
` MR. SMITH: If we're introducing things on
`the record, I don't think we have to necessarily mark
`them. It doesn't really matter. Since those are in
`the record, I don't think they necessarily need to be
`marked and attached.
` MR. HADLEY: I'll --
` MR. SMITH: It just doesn't matter.
` MR. HADLEY: It will just be easier for
`the deposition --
` MR. SMITH: That's fair.
` MR. HADLEY: -- if we have the exhibit
`numbers.
` MR. SMITH: No big deal to me.
`BY MR. HADLEY:
`
`202-220-4158
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`Henderson Legal Services, Inc.
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`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` Q. Okay. Dr. Wright, I handed you Exhibit 1,
`which is a Petition For Inter Partes Review of the
`'183 patent and this is labeled attorney document
`39521-0062 IP4.
` Do you have that in front of you?
` A. Well, I have two documents with that
`number. Both the declaration and the petition have
`that same number on them.
` Q. If I can refer you to Exhibit 1 that you
`have --
` A. Okay.
` Q. -- in front of you.
` A. Yeah, I have Exhibit 1 and related
`Exhibit 2.
` Q. And is Exhibit 1 the Petition For Inter
`Partes Review --
` A. Yes.
` Q. -- for the 39521?
` A. Yes.
` Q. And have you seen this document before?
` A. Yes.
` Q. Have you read it?
`
`202-220-4158
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`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` A. It's been some time, but I have reviewed
`it. I, of course, spent much more time recently on
`my declaration.
` Q. Okay. And then is Exhibit 2 your
`declaration in support of the petition that's marked
`as Exhibit 1?
` MR. SMITH: Objection, form.
` THE WITNESS: Well, I'm not an attorney
`but, as I understand it, my declaration relates to
`that petition with the corresponding number ending in
`IP4.
`BY MR. HADLEY:
` Q. Okay. And do you know whether Exhibit 2
`pertains to what we've been calling the 358 IPR?
` A. That's always confusing. I believe it
`does -- well, 358, 359 and 360. I believe that this
`corresponds to the 358 IPR. But -- and this always
`bothers me, it's not labeled as such.
` Q. That bothers me, also.
` A. I think that's a source of some confusion
`at times.
` Q. I -- so I'll represent to you that it is
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`202-220-4158
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`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`358.
` A. Okay.
` Q. And in fact, if you would like to write
`"358" on both of those documents, that's fine with me
`if it will help you remember as we go through these.
` A. I don't -- it's not a bad idea. I don't
`have a pen. If someone would give me a pen, I would
`write that number in either direction because it
`could help.
` (The Court Reporter hands the witness a
`pen.)
` (The witness writes the requested
`designation on Exhibit Number 2.)
` MR. HADLEY: Yeah.
` MR. SMITH: I'll just state in my defense
`that we didn't have the preceding numbers when we
`filed them, so that's why they're not on there.
` MR. HADLEY: Oh, come on, excuses,
`excuses.
` MR. SMITH: I know.
` MR. HADLEY: Okay. Let me have this
`marked as the next exhibit.
`
`202-220-4158
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`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` (Wright deposition Exhibit Number 3 was
`marked for identification and attached to the
`transcript.)
` MR. HADLEY: And let's do this as 4.
` (Wright deposition Exhibit Number 4 was
`marked for identification and attached to the
`transcript.)
`BY MR. HADLEY:
` Q. Okay. So Dr. Wright, I've handed you two
`more documents. Exhibit 3 is another Petition For
`Inter Partes Review, and is it your -- this in the
`upper right-hand corner, the number is 0062IP5.
` Is it your understanding that this
`Petition For Inter Partes Review pertains to the 359
`petition or is the 359 petition?
` A. That's my recollection, yeah.
` Q. And then Exhibit 4, is this your
`declaration that pertains to the 359 petition?
` A. Yes.
` Q. And if you'd like to go ahead and write
`"359" on those, that's fine?
` THE WITNESS: If somebody can supply me a
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`pen, I'll do it.
` (The Court Reporter hands the witness a
`pen.)
` (The witness writes the requested
`designation on Exhibit Number 4.)
`BY MR. HADLEY:
` Q. Before we go any further, have you had
`your deposition taken before?
` A. Ever?
` Q. Yes, ever.
` A. Not in regard to this matter.
` Q. In any matter whatsoever?
` A. Okay. Yes, I've had a few prior
`depositions on other patent matters.
` Q. Were those patent matters in which you
`testified as an expert?
` A. Yes.
` Q. Were they -- what kind of matters were
`they? Were they court proceedings or IPR's or
`something else?
` A. Primarily IPR's. There may have been a
`district court -- no, I think, I think all the ones I
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`was asked to provide a declaration, deposition for
`were IPR's. I could be mistaken on that, there may
`have been one district court litigation there, but
`it's been over a period of several years.
` Q. Have you ever testified in trial?
` A. No.
` Q. Do you understand that you're under oath
`for this deposition, just as you would be if we were
`in a court of law or in front of the patent office?
` A. Yes.
` Q. And do you understand that you are
`required to provide responsive answers to any
`questions that I ask, subject to objections?
` MR. SMITH: Objection, form.
` THE WITNESS: It's my understanding that
`objections can be made. It's been my experience that
`I still have to provide a response.
`BY MR. HADLEY:
` Q. Is there any reason why you cannot respond
`to questions today?
` MR. SMITH: Objection, form.
` THE WITNESS: If I don't lose my voice and
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`I have an opinion that's relevant to my declaration,
`I can't see why I couldn't respond, no.
`BY MR. HADLEY:
` Q. Is there any reason why you can't give
`truthful and honest testimony today?
` A. No.
` Q. Are you being compensated for your time in
`this case?
` A. Yep. Yes.
` Q. At what rate?
` A. My individual rate, which is not reflected
`in the invoicing because there was an intervening
`broker involved and I -- I'm not sure I know exactly
`what their markup, their additional incremental
`charges, but my rate for this project is $350 per
`hour.
` Q. Your invoices for work in this case
`reflect $350 an hour?
` A. My invoices to the agency that I work with
`are for that amount, correct.
` Q. And can you --
` A. I -- I'm sorry.
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` Q. Can you estimate for me the amount of time
`that you have spent working on the IPR's
`collectively?
` A. I don't have my billings in front of me or
`my invoices in front of me. Let's see, this is
`September. It's difficult for me to, you know,
`provide, you know, an exact hourly amount -- amount
`to the hour, but it's probably on the, on the order
`of 60 to 80 hours maximum.
` Q. And that was for all six IPR's?
` A. Correct. On -- for the '183 patent, yeah.
` Q. Right.
` Can you estimate for me the number of
`hours you've spent in connection with the 358 and 359
`IPR's?
` MR. SMITH: Objection, form.
` THE WITNESS: Hmm. Again, I don't have
`that, those files, in front of me, but I would
`probably divide it, since it's two-thirds of the
`documents in one manner of speaking, I would say it's
`probably two-thirds of that time range that I
`provided.
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`BY MR. HADLEY:
` Q. When you say two-thirds, I'm not sure.
`How did you calculate two-thirds?
` A. Well, you mentioned --
` Q. There are six IPR's.
` A. I'm sorry, I was thinking three IPR's,
`that's where I came up with that.
` So if we take into account all six
`petitions and two rounds, let's say. So there are
`six, of which we're talking about two of the six. So
`it would be on the order of one-third. And, again,
`that's just based on proration.
` Q. Did you do anything to prepare for your
`deposition?
` MR. SMITH: Objection, form.
` THE WITNESS: I, of course, reviewed my
`declaration and some of the related materials and the
`patents in particular that were cited and references
`and met with counsel yesterday.
`BY MR. HADLEY:
` Q. Did you meet with counsel to prepare for
`your deposition today?
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` MR. SMITH: Object to form.
` THE WITNESS: Today?
` MR. HADLEY: Yes.
` THE WITNESS: No, we just drove over.
`Just rode over in the car today.
`BY MR. HADLEY:
` Q. Yesterday was your meeting with counsel to
`prepare for your deposition today?
` A. Correct, yes.
` Q. And did you have any other meetings with
`counsel to prepare for your deposition, besides
`yesterday?
` A. In-person meetings?
` Q. Or phone?
` A. We had no other in-person meetings during
`this whole period, although we were in occasional
`telephone contact to discuss the matters at hand.
` Q. So you -- have you had telephone, did you
`have telephone conversations with counsel to prepare
`for your deposition today?
` A. I think I had one brief telephone
`conversation on -- today is Thursday. On Monday
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`202-220-4158
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`www.hendersonlegalservices.com
`
`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`afternoon, simply by way of confirming the logistics
`and trying to get up to date on case status,
`basically.
` Q. How long did you meet with counsel
`yesterday to prepare for your deposition?
` A. I think we -- we met commencing at ten
`a.m. and were finished our substantive discussions by
`about five or 5:30 yesterday.
` Q. Which counsel was that?
` MR. SMITH: Objection, form.
` THE WITNESS: Three gentlemen were
`involved: This gentleman, this gentleman and another
`attorney at the firm, Jeremy Monaldo.
`BY MR. HADLEY:
` Q. But when you said "this gentleman and this
`gentleman," these are the two attorneys that are
`appearing with you today?
` A. Correct, Ryan and Dan.
` Q. As I understand it, you reside in Fort
`Collins now?
` A. Yes.
` Q. And you provided a summary of your
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`
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`background and experience in the declarations marked
`as Exhibit 2 and Exhibit 4, is that right?
` A. Correct.
` Q. Is there any experience that you have that
`you believe relevant to these matters that you did
`not include in your declarations?
` A. I don't think so. The -- the -- the kind
`of biographical background information is necessarily
`brief and condensed, but I think in particular with
`regard to 15 years or so of consulting activities,
`it's probably not comprehensive with every last
`project I've worked on. But it's both representative
`in general and I believe I've called out specifically
`where the subject matter that's under discussion
`might be related.
` Q. So there's nothing you want to add to your
`background and experience if I gave you the
`opportunity to do so now?
` A. Not at this time.
` Q. Have you done -- ever done any work on
`capacitive touchscreen technology?
` A. I have worked on various aspects of -- so
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
`
`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`the base technologies involved with touchscreens,
`touchscreen displays, as well as their application as
`the input user device for hand-held products and for
`earlier type products, like touch pads for mobile
`devices and notebook computers and things like that,
`which are opaque. They're not meant for use over a
`display, but they're an earlier form of capacitive
`position sensing.
` Q. What do you mean by base technologies?
` A. Well, one of my projects for a client
`involved understanding, helping him understand what
`the optical characteristics of a touch sensor film
`were that incorporated a copper metal mesh in place
`of the conventional indium tin oxide transparent
`metal oxide films. And my particular expertise, I
`was brought into this because I have a substantial
`background in display technologies and have worked
`quite a bit with other experts on display human
`factors and display metrology.
` And the firm that was developing the metal
`mesh touch sensor was very interested in developing a
`touch sensor that would be, one, economical, he could
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`202-220-4158
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`September 26, 2019
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`market successfully, but that also wouldn't degrade
`the performance of that display. In other words,
`this metal mesh, unlike transparent indium tin oxide,
`metal oxide films that are used in most touch sensors
`for mobile devices, at least smaller displays, as --
`as the term "transparent" would convey, they're
`largely transparent. Copper metal mesh is opaque to
`light. And so in order for that copper metal mesh to
`be largely transparent and not interfere with the
`performance of the display, it has to be rendered
`into very, very fine lines, you can imagine.
` And some of the problems that result from
`that are reduced transmission, but, more importantly,
`effects like light scattering that sends light that
`would otherwise go directly from the display to the
`viewer's eye, it gets scattered in diffuse directions
`or in specular waves in particular directions, all of
`which would impair the display performance.
` So I worked with my client, who was
`developing the product, and also with a world-class
`display human factors person and a world-class
`display metrologist to define a program of display
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`202-220-4158
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`characterization with this touch sensor in place that
`would enable us to help them optimize the
`transmission characteristics of their metal mesh
`touch sensor. So that's one aspect in which I've
`worked in, let's say, the underlying base technology
`for a touch sensing system.
` Q. Would it be fair to say that your primary
`field of expertise is in displays?
` MR. SMITH: Objection, form.
` THE WITNESS: Not -- no, not in generally
`because I've worked in many different fields, all of
`which are firmly grounded in essentially material
`science and the application of materials in device
`and system applications. And basically almost all of
`the developments we have today, such as notebook
`computers and mobile devices, have been enabled by
`these advances in material science, and so it's been
`my basic understanding of the chemistry and physics
`and solid state physics of materials that has enabled
`me to apply my expertise to both device applications,
`let's say light-emitting diodes or semiconductor
`lasers for fiber optic communications, or for the use
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`202-220-4158
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`
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`of light-emitting diodes and organic light emitting
`diodes in liquid crystal display materials in
`displays.
` And basically as my career advanced, I
`became more and more involved, for example, during
`the 1990's at Motorola, in applying technologies to
`mobile devices and systems. And So I kind of moved
`higher in the food chain, if you will, as far as
`applying those base knowledge to advanced the
`technology overall.
` Q. Maybe you could make it a little simpler
`for me. If you were talking to, say, a high school
`science class and you were a guest speaker, how would
`you describe your field of expertise?
` MR. SMITH: Objection, form.
` THE WITNESS: First of all, I probably
`wouldn't explain all the various things I've done
`because it's -- it's too diverse. On the other hand,
`I would point out that when I was an undergraduate
`engineer student at Purdue University, because of my
`wide interest in applying materials, I left the
`School of Electrical Engineering and joined the newly
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`September 26, 2019
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`formed school called the School of Interdisciplinary
`Engineering. And it was one of the best things I
`ever did, even though it was kind of a somewhat of a
`concern because an electrical engineering degree was
`well understood and I was going to receive a Bachelor
`of Science in engineering and that's not so clearly
`understood. But I would come out with a Bachelor of
`Science in engineering from the School of
`Interdisciplinary Engineering, Purdue University with
`an emphasis on the electrical and metallurgical
`properties in materials. I'm sorry, the electronic
`and metallurgical properties of materials.
` And that background at Purdue allowed me
`to go on, and when I went to the University --
`University of Illinois, I did in fact move into the
`School of Electrical Engineering, rather than physics
`or chemistry or material science, and commenced my
`graduate career in applying my knowledge and interest
`in material science to development of light-emitting
`diodes and semiconductor lasers.
` Q. Have you ever designed a touchscreen
`device, capacitive -- let me restate.
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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` Have you ever designed a capacitive
`touchscreen device?
` A. I've helped design certain aspects, as I
`mentioned that metal -- for example, that metal mesh
`touch sensor layer. I certainly was influential in
`assisting my client in optimizing the design of his
`metal mesh touch sensor product for its intended
`purpose. And I've also, I managed teams that
`incorporated touch sensing devices in prototype
`products of -- during the 1990's, for example, at
`Motorola, we were developing what we would today call
`a smart phone but working on applying some advanced
`technologies, such as new display technologies and
`new user interface design paradigms for input-output
`devices, such as touch pads, pointing sticks, such as
`are on this ThinkPad.
` And as the input mechanism and my work on
`display technology that was integrating this had to
`do, these were near-to-the-eye displays that you
`looked at a magnified image of a very small display,
`much as are used in augmented reality or virtual
`reality headsets today, but this was 20 -- 20 years
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`202-220-4158
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`Case IPR2019-00358; IPR2019-00359
`Wright, Ph.D., Phillip D.
`September 26, 2019
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`ago.
` And we integrated these various
`technologies along work, for example, color VGA CMOS
`image sensors to incorporate a camera. And my final
`project at Motorola about 1998 time frame was to
`attempt to develop a prototype of a digital phone
`with a Windows CE operating system with a touch pad
`user interface and a color quarter VGA display that
`implemented the user interface of the telephone and
`acted as a viewfinder for the VGA CMOS color camera
`and operated over one of the first digital cell phone
`networks that were in use at that time, the IDEN
`system of Motorola, when all other phones were
`essentially analogue phones and couldn't exchange
`data very effectively with networks as -- as a
`digital phone could.
` Q. Have you ever personally designed a
`capacitive touch circuit?
` A. Circuit?
` Q. Yes.
` A. So a circuit would consist of electronics,
`transistors and the like, and I've certainly analyzed
`
`202-220-4158
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`
`
`Case IPR
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