Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________________________________
`LG ELECTRONICS INC.
`Petitioner
`v.
`IMMERVISION, INC.
`Patent owner
`________________________________
`IPR2020-00179
`IPR2020-00195
`
`Patent No. 6,844,990
`_______________________________
`REMOTE EXAMINATION of DAVID AIKENS
`_______________________________
`TAKEN ON
`THURSDAY, OCTOBER 1, 2020
`
`CERTIFIED STENOGRAPHER:
`JESSIE WAACK, RDR, CRR, CCRR, CCR, NYACR, NYRCR
`REALTIME SYSTEMS ADMINISTRATOR
`JOB NO.: 49143
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 1 of 324
`
`
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________________________________
`LG ELECTRONICS INC.
`Petitioner
`v.
`IMMERVISION, INC.
`Patent owner
`________________________________
`IPR2020-00179
`IPR2020-00195
`
`Patent No. 6,844,990
`_______________________________
`REMOTE EXAMINATION of DAVID AIKENS
`_______________________________
`TAKEN ON
`THURSDAY, OCTOBER 1, 2020
`
`CERTIFIED STENOGRAPHER:
`JESSIE WAACK, RDR, CRR, CCRR, CCR, NYACR, NYRCR
`REALTIME SYSTEMS ADMINISTRATOR
`JOB NO.: 49143
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 1 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`2
`
`REMOTE EXAMINATION of DAVID AIKENS,
`taken before JESSICA R. WAACK, Registered
`Professional Reporter, Registered Merit
`Reporter, Certified Realtime Reporter,
`Registered Diplomate Reporter, California
`Certified Realtime Reporter, Certified Court
`Reporter in New Jersey, New York Association
`Certified Reporter, New York Realtime Court
`Reporter and Notary Public of the State of New
`York, proceedings held via videoconference, on
`Thursday, October 1, 2020, commencing at
`11:04 a.m. EDT and concluding at 5:18 p.m.
`EDT.
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`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 2 of 324
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`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`3
`
`A P P E A R A N C E S
`(all appearing remotely)
`ON BEHALF OF THE PETITIONER:
` MORGAN LEWIS & BOCKIUS LLP
` BY: DION M. BREGMAN, ESQ.
` 1400 Page Mill Road
` Palo Alto, California 94304-1124
` PHONE: 650-843-7519
` EMAIL: Dion.bregman@morganlewis.com
`-and-
` MORGAN LEWIS & BOCKIUS LLP
` BY: BRADFORD A. CANGRO, ESQ.
` 1111 Pennsylvania Avenue NW
` Washington, D.C. 20004-2541
` PHONE: 202-739-5088
` EMAIL: Bradford.cangro@morganlewis.com
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`www.hendersonlegalservices.com
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`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 3 of 324
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`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`4
`
`APPEARANCES CONTINUED:
`
`ON BEHALF OF THE PATENT OWNER:
` PANITCH SCHWARZE BELISARIO & NADEL LLP
` BY: STEPHEN E. MURRAY, ESQ.
` 2001 Market Street, Suite 2800
` Philadelphia, Pennsylvania
` 19103-7044
` PHONE: 215-965-1307
` EMAIL: SMurray@panitchlaw.com
` -and-
` PANITCH SCHWARZE BELISARIO & NADEL LLP
` BY: JOHN D. SIMMONS ESQ., ESQ.
` 2200 Concord Pike, Suite 201
` Wilmington, Delaware 19803
` PHONE: 302-394-6021
` EMAIL: Jsimmons@panitchlaw.com
`
` A L S O P R E S E N T
`RUSSELL A. CHIPMAN, Expert for Petitioner
`
` --o0o--
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 4 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`5
`
` INDEX TO EXAMINATION
` WITNESS: DAVID AIKENS
`EXAMINATION PAGE
` BY MR. BREGMAN 7
`
` -o0o-
` INFORMATION REQUESTED
` None
`
` WITNESS INSTRUCTED NOT TO ANSWER
` None
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 5 of 324
`
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`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`6
`
` INDEX TO PREVIOUSLY MARKED EXHIBITS
` WITNESS: DAVID AIKENS
` Thursday, October 1, 2020
`MARKED DESCRIPTION PAGE
`Exhibit 1001 U.S. Patent 6,844,990 13
`Exhibit 1005 U.S. Patent 5,686,957 262
`Exhibit 2009 Mr. Aiken's declaration 14
`Exhibit 2012 Pedrotti reference 253
`
` ** No exhibits were included in the
` transcript **
`
` --o0o--
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 6 of 324
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`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`7
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` ******
` PROCEEDINGS
` October 1, 2020, 11:04 a.m.
` New York, New York
` ******
` DAVID AIKENS
` called as a witness herein, having
` been first duly sworn on oath, was
` examined and testified as follows:
` EXAMINATION
` BY MR. BREGMAN:
` Q. Hi, Dr. Aikens. Dion Bregman here.
`11:04:42
` We just met. So we are going to go through
`11:04:45
` just a couple of introductory questions related
`11:04:49
` to depositions.
`11:04:51
` So have you ever had your deposition
`11:04:51
` taken before?
`11:04:54
` A. Yes, I have.
`11:04:55
` Q. How many times?
`11:04:56
` A. I've testified once, and I think
`11:04:57
` I've been deposed three times, so this will be
`11:05:04
` my fourth.
`11:05:06
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 7 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`8
` Q. What was the most recent one?
`11:05:07
` A. July -- I want to say 20th, on that
`11:05:09
` order.
`11:05:16
` Q. Are these all patent cases?
`11:05:17
` A. No. Some are patents, some are
`11:05:19
` contract law.
`11:05:21
` Q. And the most recent one was a patent
`11:05:23
` case?
`11:05:26
` A. The most recent one is a civil case.
`11:05:27
` Q. And the one in July, that was also
`11:05:29
` via videoconference?
`11:05:34
` A. That was videoconference, yes.
`11:05:37
` Q. So we'll go through some sort of
`11:05:39
` basic ground rules which I'm sure you've heard
`11:05:41
` a million times before, and then we'll talk
`11:05:44
` about a remote deposition. That's a little bit
`11:05:47
` different.
`11:05:49
` All your answers need to be verbal
`11:05:49
` responses, of course. It's particularly
`11:05:51
` important now because we're not all sitting
`11:05:54
` together, and Jessica, our court reporter,
`11:05:57
` needs to hear your response, not a nod of the
`11:05:59
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 8 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`9
` head, for example.
`11:06:01
` Is that okay with you?
`11:06:02
` A. Yes.
`11:06:05
` Q. If you don't understand a question
`11:06:06
` and you need clarification, just feel free to
`11:06:08
` ask me to rephrase the question.
`11:06:11
` We're going to be taking a break
`11:06:13
` about every hour. Of course, if you need a
`11:06:15
` break at any other time, just let me know, and
`11:06:17
` we can take a break. I just ask that you
`11:06:21
` finish answering the line of questions that we
`11:06:23
` are busy dealing with at the time.
`11:06:25
` Do you understand that you are under
`11:06:29
` oath as if testifying in a court of law?
`11:06:31
` A. Yes, I do.
`11:06:35
` Q. Is there any reason why you can't
`11:06:37
` answer my questions fully and truthfully today?
`11:06:39
` A. No, there is not.
`11:06:41
` Q. Are you taking medication that would
`11:06:43
` affect your testimony?
`11:06:45
` A. No, I'm not.
`11:06:47
` Q. All right. Since we're not in
`11:06:49
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 9 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`10
` person, I'm going to ask a couple of additional
`11:06:52
` questions.
`11:06:54
` What materials do you have in front
`11:06:55
` of you or available?
`11:06:57
` A. So on my left I have my laptop
`11:06:59
` computer with the window open which includes
`11:07:03
` all of the documents that you sent yesterday.
`11:07:06
` Q. Okay.
`11:07:09
` A. On my right, I have some paper
`11:07:10
` copies of the same documents, specifically my
`11:07:13
` declaration, Dr. Chipman's declaration, and the
`11:07:17
` relevant patents in the case.
`11:07:20
` Q. All right. And do you have any
`11:07:22
` flags or markings on any of those documents?
`11:07:24
` A. No, I do not.
`11:07:28
` Q. Okay. I apologize if I keep
`11:07:29
` clearing my throat, but it's super smoky here
`11:07:33
` in California today.
`11:07:36
` A. I'm sorry.
`11:07:37
` Q. No problem.
`11:07:37
` So I'm going to ask you to refrain
`11:07:38
` from looking up anything or things on your
`11:07:44
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 10 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`11
` computer other than the documents that we are
`11:07:47
` discussing; is that okay?
`11:07:50
` A. I understand.
`11:07:51
` Q. And you'll let me know if you're
`11:07:52
` looking at any of the other documents in front
`11:07:54
` of you other than the ones I've directed your
`11:07:56
` attention to, right?
`11:08:00
` A. Yes.
`11:08:02
` Q. I also ask that you refrain from
`11:08:02
` using chat or instant messaging features on
`11:08:04
` your computer or phone while I'm -- until I'm
`11:08:07
` finished asking my questions today; is that
`11:08:12
` okay?
`11:08:14
` A. Yes.
`11:08:15
` Q. Thanks.
`11:08:15
` Finally, just like a regular
`11:08:19
` deposition, you're forbidden from discussing
`11:08:21
` your testimony with your counsel until I'm done
`11:08:23
` asking you questions.
`11:08:26
` Do you understand that?
`11:08:26
` A. Yes.
`11:08:28
` Q. Okay. So do you understand that
`11:08:29
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 11 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`12
` you're testifying today with respect to two IPR
`11:08:33
` proceedings, IPR 2020-00179 and IPR 2020-00195?
`11:08:35
` A. I'm going to reach for my
`11:08:45
` deposition.
`11:08:50
` Q. Okay.
`11:08:50
` A. Yes, that's correct.
`11:08:51
` Q. When you say your deposition, you
`11:08:53
` mean your declaration?
`11:08:54
` A. Sorry. My declaration, yes.
`11:08:55
` Q. And I'm just going to refer to them
`11:08:57
` as the IPRs; is that okay?
`11:08:59
` A. That's fine.
`11:09:02
` Q. And is it correct that you provided
`11:09:03
` a single declaration for both of these IPRs?
`11:09:06
` A. That's correct.
`11:09:09
` Q. Now, the questions asked today are
`11:09:10
` going to be applicable for both proceedings.
`11:09:14
` If you believe that your answer would vary
`11:09:16
` between the proceedings, please note that or
`11:09:18
` ask me to clarify my question.
`11:09:22
` Is that okay?
`11:09:23
` A. I understand.
`11:09:24
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 12 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`13
` Q. Why don't we look at Exhibit 1001.
`11:09:26
` And that's U.S. Patent 6,844,990.
`11:09:38
` A. I have it.
`11:09:47
` Q. And is this the patent that you've
`11:09:47
` provided your opinions on?
`11:09:51
` A. Yes, it is.
`11:09:54
` Q. And has the patent been --
`11:09:56
` (Audio technical difficulties;
`11:10:06
` stenographer asks for
`11:10:06
` clarification.)
`11:10:07
` BY MR. BREGMAN:
`11:10:07
` Q. And it is the patent that is being
`11:10:07
` challenged in the IPRs, right?
`11:10:09
` A. Yes.
`11:10:11
` Q. And I'm going to refer to it as
`11:10:15
` either "the '990 patent" or "the patent."
`11:10:16
` Is that okay?
`11:10:20
` A. Yes.
`11:10:21
` Q. And you recognize this Exhibit 1001?
`11:10:21
` You've seen it before?
`11:10:25
` A. I do.
`11:10:26
` Q. Why don't you briefly tell me what
`11:10:27
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 13 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`14
` you believe the invention to be in the '990
`11:10:31
` patent.
`11:10:35
` A. Well, I'd like to refer to my
`11:10:36
` declaration, because I spent quite a bit of
`11:10:42
` time preparing it.
`11:10:45
` Is that all right?
`11:10:46
` Q. Yeah, that's okay.
`11:10:49
` A. So as I say in paragraph 25 of my
`11:10:52
` declaration, "The '990 patent relates to
`11:11:10
` panoramic imaging and display."
`11:11:16
` Q. Before we get there, why don't we
`11:11:17
` just introduce your declaration.
`11:11:19
` So you're talking about
`11:11:21
` Exhibit 2009?
`11:11:23
` A. That's correct.
`11:11:24
` Q. And that's -- if you go to the very
`11:11:24
` last page, that's your signature?
`11:11:27
` A. Yes, it is.
`11:11:29
` Q. Okay. And this is the declaration
`11:11:30
` that we discussed earlier that discusses both
`11:11:32
` of the patents in the IPR? Sorry. Both of
`11:11:35
` the -- discusses the '990 patent from both of
`11:11:39
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`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 14 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`15
` the IPRs?
`11:11:42
` A. That's correct.
`11:11:45
` Q. Okay. Sorry. I cut you off. Why
`11:11:46
` don't you continue telling me about the
`11:11:50
` inventions.
`11:11:52
` A. Well, as you can see from my
`11:11:55
` Section 6, I go through the patent and the
`11:11:59
` claim summary. I'm not exactly sure what you
`11:12:02
` specifically want to know.
`11:12:05
` Q. I just want to know sort of in a
`11:12:06
` nutshell what you believe the invention of the
`11:12:08
` patent, the '990 patent is all about.
`11:12:12
` A. Well, it is about panoramic imaging
`11:12:17
` and display.
`11:12:22
` Q. Panoramic imaging and display, of
`11:12:23
` course, is --
`11:12:26
` A. I'm sorry. Could you repeat that?
`11:12:27
` You're breaking up a little.
`11:12:28
` Q. Panoramic imaging and display, in
`11:12:29
` and of itself is not new, right?
`11:12:34
` A. Panoramic imaging dates back to
`11:12:36
` roughly to the 1840s.
`11:12:41
`
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 15 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`16
` Q. Okay. And display of panoramic
`11:12:43
` images is also very old, right?
`11:12:46
` A. Same time frame. Thomas Sutton's
`11:12:48
` panoramic camera.
`11:12:52
` Q. Okay. So what is the invention, in
`11:12:53
` a nutshell, of the '990 patent?
`11:12:55
` A. Well, as the patent explains in
`11:12:57
` prior art, a panoramic imaging lens would have
`11:13:01
` a linear relationship -- might have a linear
`11:13:05
` relationship between the angles of field in
`11:13:08
` object space and the height of the image in
`11:13:12
` image space. The '990 patent -- I'm sorry.
`11:13:16
` No, please.
`11:13:21
` Q. No, go ahead.
`11:13:22
` A. No, I was finished. That's fine.
`11:13:25
` Q. Okay. So I think what you're
`11:13:27
` talking about is if we go back to the patents,
`11:13:29
` Exhibit 1001, we're looking at Figure 4A and
`11:13:32
` 4B; is that correct?
`11:13:39
` A. That's correct.
`11:13:39
` Q. So maybe you can start with that and
`11:13:39
` explain to me what's shown in Figure 4A and 4B
`11:13:41
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`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 16 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`17
` and tell me what -- what the invention is.
`11:13:44
` A. Well, actually, first we should look
`11:13:47
` at Figure 5.
`11:13:50
` Q. Okay.
`11:13:51
` A. Figure 5 puts the context -- puts
`11:13:52
` the invention in a little better context. This
`11:13:55
` is the prior art.
`11:13:58
` Q. Uh-huh.
`11:14:01
` A. So this figure describes a series of
`11:14:03
` angles in object space and a series of heights
`11:14:05
` in image space. And it shows a linear
`11:14:09
` relationship between the angle and the height
`11:14:12
` on the detector.
`11:14:15
` In the patent, it specifically
`11:14:16
` describes the Angle A2 as being half of A1. In
`11:14:19
` this particular figure, A1 is drawn
`11:14:25
` incorrectly. It should extend from line A all
`11:14:28
` the way to the optical axis.
`11:14:30
` So A2 is half of A1. And similarly,
`11:14:33
` the image of those -- the image point related
`11:14:36
` to those object points are A prime and B prime
`11:14:38
` at the image plane, and they would have heights
`11:14:41
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 17 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`18
` of D1 and D2 respectively, and D2 is one-half
`11:14:44
` of D1. This is called a linear field
`11:14:49
` relationship, or H equals F theta, commonly
`11:14:52
` referred to as an F-theta lens.
`11:14:57
` Q. Just looking at the arrow for D1 and
`11:14:59
` D2, should there be arrow points on that center
`11:15:02
` line, or does D1 extend all the way from one
`11:15:05
` side to the other side?
`11:15:10
` A. No, you're correct. Those are -- D1
`11:15:11
` extends below the center line, and negative D1
`11:15:14
` extends above the center line. So D2 goes
`11:15:19
` below the center line and negative D2 goes
`11:15:22
` above the center line.
`11:15:27
` Q. Okay. So I think I got that.
`11:15:28
` So if we go back to Figure 4A and
`11:15:29
` 4B, how does that apply to what we just
`11:15:32
` discussed with respect to Figure 5?
`11:15:34
` A. Okay. So that is a linear
`11:15:36
` relationship between field angle and image
`11:15:37
` height. If you look at Figure 4A, it shows a
`11:15:39
` series of concentric circles, each of which is
`11:15:42
` from a different field height, specifically 10
`11:15:47
`
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 18 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`19
` degrees, 20 degrees, 30 degrees and so on.
`11:15:51
` In this particular case, the lens in
`11:15:54
` question is imaging over plus or minus 90
`11:15:58
` degrees diameter. So there is the -- the
`11:16:00
` circles relating to the field angles are C10,
`11:16:05
` C20 and so on up to C90.
`11:16:09
` Q. Uh-huh. And lenses are always round
`11:16:12
` or circular, as you said?
`11:16:16
` A. I'm just describing this figure.
`11:16:17
` Q. Okay. And my question just
`11:16:20
` generally, are lenses always circular?
`11:16:22
` A. That's -- that's a very broad
`11:16:24
` question. In what context? In this patent?
`11:16:27
` Q. In this patent.
`11:16:31
` A. In this patent.
`11:16:32
` Q. Are lenses circular?
`11:16:33
` A. No, I believe not. We'll have to
`11:16:36
` look at a different figure. Should we leave
`11:16:39
` this line for the moment?
`11:16:42
` Q. Why don't we look at that figure.
`11:16:42
` We'll come back in a second.
`11:16:44
` A. In this patent, there is Figure 18,
`11:16:45
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 19 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`20
` for example. And these are not necessarily
`11:16:51
` round or square or -- although we're not --
`11:16:55
` they could have any shape depending on the type
`11:17:01
` of lens.
`11:17:03
` Q. I see.
`11:17:03
` A. Although -- although there are no
`11:17:04
` figures to this effect, you could also have
`11:17:06
` anamorphic lenses where you have different
`11:17:08
` shapes in the two directions, for example.
`11:17:11
` Lenses can be elliptically shaped, they could
`11:17:12
` be round, they could be square.
`11:17:16
` Q. I'm looking at Figure 18. How can
`11:17:18
` you tell from Figure 18 that the lenses are not
`11:17:20
` circular?
`11:17:22
` A. Well, Figure 18 uses a pair of
`11:17:23
` mirrors.
`11:17:25
` Q. Uh-huh.
`11:17:25
` A. You see the second mirror has a disc
`11:17:26
` shape to it.
`11:17:30
` Q. Yep.
`11:17:30
` A. An optical imaging system which is
`11:17:33
` used at an off-axis angle is very rarely round.
`11:17:35
`
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`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 20 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`21
` Q. I see. What shape would that
`11:17:40
` normally have?
`11:17:42
` A. Like I said, it could be elliptical,
`11:17:43
` it could be square, it could be rectangular.
`11:17:47
` Q. Sticking with Figure 18, what is
`11:17:50
` No. 43?
`11:17:52
` A. I'm not sure. I'll have to take a
`11:17:53
` look at the specification, if that's all right.
`11:17:57
` Q. Sure.
`11:17:59
` A. The beam is deflected by the mirror,
`11:18:00
` M2 is sent onto an Image Sensor 43. So Item 43
`11:18:17
` in Figure 18 is the image sensor.
`11:18:22
` Q. Are imaging sensors -- what shape
`11:18:24
` are image sensors normally?
`11:18:26
` A. In this particular case, I don't
`11:18:28
` believe the specification says what the shape
`11:18:31
` of the image sensor is. The sensors, again,
`11:18:33
` come in lots of different shapes and sizes.
`11:18:36
` Q. You can get a circular image
`11:18:38
` sensors?
`11:18:39
` MR. MURRAY: Objection to form.
`11:18:43
` THE WITNESS: Speaking in the
`11:18:49
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`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 21 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`22
` context of, like -- like a camera or in the
`11:18:51
` context of a satellite? What...
`11:18:55
` BY MR. BREGMAN:
`11:19:00
` Q. I'm not sure what's the difference
`11:19:00
` between a satellite and a camera.
`11:19:01
` A. Well, I guess the simplest answer is
`11:19:05
` sensors come in lots of different shapes.
`11:19:07
` Q. Do they come in shapes that are
`11:19:09
` circular?
`11:19:11
` A. Well, so first of all, there's --
`11:19:12
` there is a difference between an image sensor
`11:19:23
` and a camera.
`11:19:25
` So, I mean, that's why the question
`11:19:25
` is so vague, it's very difficult for me to
`11:19:27
` approach it. But if you consider Item 43,
`11:19:30
` which is an image sensor, you can certainly get
`11:19:32
` round image sensors. They do exist.
`11:19:35
` Q. You say there's a difference between
`11:19:39
` a camera and an image sensor. What's the
`11:19:41
` difference?
`11:19:43
` A. An image sensor is -- it can mean a
`11:19:43
` lot of different things, including a camera.
`11:19:47
`
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`LGE Exhibit 1018
`LGE v. ImmerVision - IPR2020-00179
`Page 22 of 324
`
`
`
`Aikens, David
`
`IPR2020-00179; IPR2020-00195
`
`October 1, 2020
`
`23
` Q. Okay. But you said a camera and an
`11:19:49
` image sensor are two different things. Why are
`11:19:53
` they different? You just said they could be
`11:19:55
` the same.
`11:19:57
` A. Well, they're different words. They
`11:19:58
` mean different things. That's what I mean. An
`11:20:00
` image sensor is a more general, broad term for
`11:20:02
` any sensor that's collecting an image.
`11:20:04
` It could be a camera or it could be
`11:20:07
` a -- it could be a CCD, a CMOS sensor. It
`11:20:11
` could be an array of microbolometers. It can
`11:20:16
` have a lot of different structure to it, some
`11:20:21
` of which we would not colloquially refer to as
`11:20:24
` a camera.
`11:20:26
` Q. And when you're talking about the
`11:20:27
` camera, you still have an image sensor inside
`11:20:29
` the camera?
`11:20:32
` A. So "camera" is really an ambiguous
`11:20:32
` term. A lot of people would call a camera,
`11:20:34
` like, the -- the device that's inside their
`11:20:37
` phone, for example, which includes an image
`11:20:40
` sensor but has a lot of other stuff too.
`11:20:43
`
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`Henderson
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