APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 2
` 1 UNITED STATES PATENT AND TRADEMARK OFFICE
`
` 2 _________________________
`
` 3 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` 4 _________________________
`
` 5 APPLE, INC.,
` Petitioner
` 6
`
` 7 vs.
`
` 8 COREPHOTONICS, LTD.,
` Patent Owner.
` 9
`
`10 ____________________________
`
`11 Case IPR2020-00877
` U.S. Patent 10,288,840
`12
` Case IPR2020-00878
`13 U.S. Patent 10,330,897
`
`14
`
`15 _____________________________
`
`16
`
`17
`
`18 VIDEO-RECORDED DEPOSITION OF JOSE SASIAN,
`
`19 Ph.D., taken remotely via Zoom at 9:06 a.m.,
`
`20 Friday, January 22, 2021, before Theresa JoAnn
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`21 Phillips-Blackwell, CSR 12700.
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`22
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`23
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`24
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`25
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`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 4
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` 1 I N D E X
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` 3 DEPONENT EXAMINED BY PAGE
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` 4 Jose Sasian Ph.D. Mr. Rubin 6
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` 7
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` 8
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` 9 EXHIBITS
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`10
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`11 (NONE MARKED)
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`12
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`13 INSTRUCTED NOT TO ANSWER
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`14 PAGE LINE
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`15 60 22
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`Page 3
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`Page 5
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` 1 APPEARANCES OF COUNSEL:
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` 2
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` 3 For Petitioner:
`
` 4 STEPHANIE SIVINSKI, ESQ.
` JORDAN M. MAUCOTEL, ESQ.
` 5 MICHAEL PARSONS, ESQ.
` (All Appearing via Zoom)
` 6 HAYNES AND BOONE, LLP
` 600 Congress Avenue
` 7 Suite 1300
` Austin, Texas 78701
` 8
`
` 9 -and-
`
`10 PRIYA B. VISWANATH, ESQ.
` (Appearing via Zoom)
`11 COOLEY LLP
` 3175 Hanover Street
`12 Palo Alto, California 94304
` (650) 849-7023
`13 pviswanath@cooley.com
`
`14
`
`15 For Patent Owner:
` NEIL A. RUBIN, ESQ.
`16 (Appearing via Zoom)
` RUSS, AUGUST & KABAT
`17 12424 Wilshire Boulevard
` Twelfth Floor
`18 Los Angeles, California 90025
` (310) 826-7474
`19
`
`20
`
`21 Also Present: John Hank, videographer
` (Appearing via Zoom)
`22
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`23
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`24
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`25
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` 1 (Remotely via Zoom; Friday, January 22, 2021, 9:06 a.m.)
` 2
` 3 THE VIDEOGRAPHER: Good morning. We're now on
` 4 the record. My name is John Hank here today for Barkley
` 5 Court Reporters. Today is January 22nd, 2021. The time
` 6 is 9:06 a.m. We are located remotely via
` 7 videoconferencing technology.
` 8 This deposition of Dr. Jose Sasian is being
` 9 taken today on behalf of the patent owner in the case
`10 captioned Apple, Inc., versus Corephotonics, LTD., in
`11 the United States Patent and Trademark Office Before the
`12 Patent Trial and Appeals Board, Case No. IPR2020-00877,
`13 Patent No. 10,288,840 and IPR2020-00878, Patent
`14 No. 10,337,897 [sic].
`15 Will counsel for the parties please identify
`16 yourselves with city and state where you are appearing
`17 from.
`18 DEPOSITION OFFICER: I think you got the patent
`19 number wrong again, John.
`20 THE VIDEOGRAPHER: Okay.
`21 MR. RUBIN: Yeah. There's an extra 7, I think,
`22 in what you read.
`23 THE VIDEOGRAPHER: All right. The court
`24 reporter will correct my audio.
`25 Would counsel please introduce yourselves.
`
`Min-U-Script®
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`Barkley Court Reporters
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`(1) Pages 2 - 5
`
`Exhibit 2003
`IPR2020-00878
`Page 1 of 48
`
`

`

`APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 6
`
`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 8
`
` 1 MR. RUBIN: This is Neil Rubin of Russ, August
` 2 & Kabat representing Patent Owner Corephotonics,
` 3 Limited.
` 4 MS. SIVINSKI: Good morning. Stephanie
` 5 Sivinski with Haynes And Boone representing Petitioner
` 6 Apple. With me today is Jordan Maucotel and Mike
` 7 Parsons, also with Haynes And Boone and also on behalf
` 8 of Apple, and then our colleague Priya Viswanath, who is
` 9 from Cooley LLP, also on behalf of Apple.
`10 THE VIDEOGRAPHER: Thank you. Will the court
`11 reporter swear in the witness remotely.
`12 DEPOSITION OFFICER: Raise your right hand,
`13 please.
`14 You do solemnly state that the evidence you
`15 shall give in this matter shall be the truth, the whole
`16 truth, and nothing but the truth, so help you God?
`17 THE WITNESS: (No audible response.)
`18 DEPOSITION OFFICER: I'm sorry?
`19 THE WITNESS: Yes.
`20 DEPOSITION OFFICER: Thank you.
`21
`22 EXAMINATION
`23
`24 BY MR. RUBIN:
`25 Q. Good morning, again, Professor Sasian.
`
` 1 explaining that to you.
` 2 I will remind you that during breaks while I'm
` 3 conducting my examination of you, you're not allowed to
` 4 have any discussions with counsel for Apple or with
` 5 anybody else about your testimony, questions I've asked,
` 6 questions you expect that I'll ask, answers that you've
` 7 given. Do you understand that?
` 8 A. Yes, I do.
` 9 MS. SIVINSKI: Just to clarify, Mr. Rubin, we
`10 can talk about issues relating to privilege; but
`11 otherwise, I agree with your description.
`12 BY MR. RUBIN:
`13 Q. And is there any reason today that you can't
`14 give full --
`15 (Technical difficulties.)
`16 DEPOSITION OFFICER: Counsel, I was kicked out
`17 of the meeting. The last -- can we go off the record?
`18 MR. RUBIN: We can go off the record.
`19 THE VIDEOGRAPHER: We're off the record at
`20 9:12.
`21 (A recess is taken.)
`22 THE VIDEOGRAPHER: We're back on the record at
`23 9:13.
`24 BY MR. RUBIN:
`25 Q. So let me ask you again. Is there any reason
`
`Page 7
`
`Page 9
`
` 1 A. Good morning.
` 2 Q. So you've been deposed a number of times in
` 3 IPRs between Apple and Corephotonics; is that right?
` 4 A. Yes.
` 5 Q. Since the last deposition that you and I had
` 6 together, have you been deposed in any other matters?
` 7 A. No, I haven't.
` 8 Q. And the last deposition that we did in Apple
` 9 versus Corephotonics matter was conducted over Zoom,
`10 like today's deposition is; correct?
`11 A. Yes.
`12 Q. So as we discussed a little bit prior to going
`13 on the record, I am going to be sharing exhibits by PDF
`14 with you using the chat function in Zoom that you'll be
`15 able to download and refer to on your computer; and I'll
`16 also be sharing my screen at least at some points to
`17 show you particular portions of exhibits.
`18 You're comfortable with accessing the documents
`19 via the chat function and using the Zoom software?
`20 A. Yes. I think so.
`21 Q. Certainly, if you have any -- any difficulties
`22 with the technology, please let me know.
`23 A. Thank you.
`24 Q. And you're -- you're familiar with the
`25 deposition process, I guess; so I won't belabor the --
`
` 1 that you can't give complete and accurate testimony on
` 2 the subjects of these two IPRs today?
` 3 A. No. I can't recall.
` 4 Q. Okay. And then I think you were starting to
` 5 say something about your Internet connection.
` 6 A. Yes. I -- the Internet here sometimes just
` 7 stops for a few seconds; so if you lose me, we should
` 8 wait maybe like one minute. I'm -- probably the
` 9 Internet will come back. But if it doesn't come back, I
`10 have my iPhone and will try to connect through my
`11 iPhone.
`12 And the second item is if my dogs -- I am alone
`13 in the house with my dogs. If my dogs start barking, I
`14 will have to bring them to the backyard. So I will
`15 briefly go and take them to the backyard. That's all.
`16 Q. Okay. Well, certainly, we'll -- we'll work
`17 together to work around any Internet connection issues
`18 and other -- other household demands that come up.
`19 Hopefully -- hopefully, things will go smoothly.
`20 All right. So let me share with you a window.
`21 So on your screen you should see the first page of
`22 Exhibit 1003 in the IPR concerning the '897 patent
`23 that's IPR2020-00878.
`24 Do you see that on your screen?
`25 A. Yes, I do.
`
`Min-U-Script®
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`Barkley Court Reporters
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`(2) Pages 6 - 9
`
`Exhibit 2003
`IPR2020-00878
`Page 2 of 48
`
`

`

`APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 10
`
`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 12
`
` 1 Q. And do you recognize this as the declaration
` 2 that you submitted in -- on behalf of Apple in that IPR?
` 3 A. It appears to be so, yes.
` 4 Q. And then on your screen now is Exhibit 1003 in
` 5 Apple's IPR concerning the '840 patent that's
` 6 IPR2020-00877.
` 7 Do you recognize this document as a declaration
` 8 that you submitted on behalf of Apple in that IPR?
` 9 A. Yes. It appears so.
`10 Q. Are there -- is there anything in either of
`11 those two declarations that you're aware of that is in
`12 error or that you'd like to correct?
`13 A. Well, in the case of the '840 declaration, I --
`14 at this moment I cannot think of any issue. In the case
`15 of '897, I am aware of a few clerical errors and an
`16 omission of a word in a couple of places or so.
`17 Q. What are the clerical errors?
`18 A. There is a misquote for a patent number in one
`19 of the paragraphs. That's related with Claim 16, I
`20 believe. There is a misquote of the total track length
`21 for the first modified lens. Right now those are the
`22 ones I can recall; but as we go, probably I can remember
`23 two -- two more or one more. I don't remember exactly
`24 right now.
`25 Q. And then you said earlier that in addition to
`
` 1 you look at this page, it says on the second paragraph,
` 2 "In more detail as discussed above the '647."
` 3 Q. Uh-huh.
` 4 A. That is not -- that is the incorrect number.
` 5 Q. That should be the '897?
` 6 A. '897.
` 7 Q. Okay.
` 8 A. And also, another -- another item I now recall
` 9 is in the previous page.
`10 Q. Uh-huh.
`11 A. Page 93.
`12 Q. Ninety-three, you said?
`13 A. Yeah. No. I'm sorry. Ninety-four. On the --
`14 on the third line it reads, "Does Chen Example 1 teaches
`15 wherein lens element L1-1"; and it should be L2_1. And
`16 at the end of the line it says "L1_2." It should be
`17 L2 --
`18 Q. L2, underscore, 2?
`19 A. That's incorrect. Those -- those two should be
`20 as in the previous page on the -- on the Claim L2_1 and
`21 L2_2.
`22 Q. Okay. So those are the errors that you're
`23 aware of for your section on Claim 16?
`24 A. Yes. As I recall right now, those are the ones
`25 that I can recall.
`
`Page 11
`
`Page 13
`
` 1 clerical errors, there was an omission of a word in a
` 2 couple of places or so. Do you recall where the words
` 3 were omitted?
` 4 A. Yes. From one of the references I am using
` 5 part of a phrase that says, "for a small format sensors
` 6 when issued before a small pixel format sensors."
` 7 So I omitted the word "pixel" in two or three
` 8 places when I referred to that phrase in one of the
` 9 references.
`10 Q. Okay. Anything else?
`11 A. Not that I can think -- think at this moment.
`12 Q. So you said that there was a misquote of a
`13 patent number in your discussion of Claim 16.
`14 A. -- our answer.
`15 Q. I'm sorry. Go ahead.
`16 A. And that would be in the chart. That would be
`17 in the chart for Claim 16.
`18 Q. Do you recall where in the chart?
`19 A. Go forward.
`20 Q. What was that?
`21 A. If you continue going down.
`22 Q. You'll tell me when to stop?
`23 A. Yes, please. You need to go to Claim 16.
`24 Q. Oh, okay. I'm sorry.
`25 A. I'll work on it. Oh, also -- here it is. If
`
` 1 Q. And then you said that there was an error in
` 2 the TTL for the first modified lens?
` 3 A. Yes.
` 4 Q. And that's your -- that's the lens based on the
` 5 combination of Ogino with Bareau; is that right?
` 6 A. That's correct.
` 7 Q. So that would be this section?
` 8 A. Yes.
` 9 Q. Starting on Page 54?
`10 A. I believe so.
`11 Q. Do you know where in this section the TTL was
`12 wrong?
`13 A. If you go down more, more, more. Right where
`14 the cross-section of the lens is. Right there. If you
`15 see on the bottom line it says, "TTL of 5.271."
`16 Q. Uh-huh.
`17 A. It is -- that number is a clerical error. It
`18 should be 5.05. The other -- but it's 5.05. Same as
`19 the total track -- the axial length in the drawing.
`20 DEPOSITION OFFICER: The axial lens in the
`21 what?
`22 THE WITNESS: As in the axial length in the
`23 drawing.
`24 DEPOSITION OFFICER: Okay.
`25 ///
`
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`(3) Pages 10 - 13
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`Exhibit 2003
`IPR2020-00878
`Page 3 of 48
`
`

`

`APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 14
`
`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 16
`
` 1 BY MR. RUBIN:
` 2 Q. I see. So it should be the same number as in
` 3 the screenshot and the -- towards the bottom right of
` 4 Page 59; is that right?
` 5 A. Yes. In the appendix, when I discuss the
` 6 number, it's -- it's properly -- it's properly given.
` 7 And it's 5.05.
` 8 Q. Okay.
` 9 A. There is -- the same error appears maybe in the
`10 next page. Let's go to the next -- next page. I think
`11 it is on -- on the chart if we go further down. At the
`12 beginning of the chart, I -- it's misquote. Rather than
`13 5.21, should be 5.05.
`14 Q. I see.
`15 A. And part of that is -- maintained is lower.
`16 That was a mistake I made.
`17 Q. I'm not sure I quite understood the sentence
`18 you just said. Can you repeat that.
`19 A. Yes. The total track is smaller than the
`20 original that -- the original total track of 5.273. So
`21 the total track length is not maintained. It's lower.
`22 Q. Uh-huh. Are there any other errors that you're
`23 aware of?
`24 A. Not that I can think. Thank you.
`25 Q. Okay. So --
`
` 1 (Telephonic interruption.)
` 2 MR. RUBIN: Was that somebody's phone?
` 3 MS. SIVINSKI: Sorry.
` 4 MR. RUBIN: That's all right. No worries.
` 5 BY MR. RUBIN:
` 6 Q. So turning to Page 37 of your declaration
` 7 concerning the '897 patent. You perform a calculation
` 8 about the Ogino Example 5 lens using the lens maker
` 9 equation from Born.
`10 Do you see that?
`11 A. Yes.
`12 Q. And Born -- we can -- let me actually share
`13 Born with you. Sorry. Sorry. It's taking a moment to
`14 upload.
`15 A. Sure.
`16 Q. So you should be able to download it now. You
`17 let me know when you're -- when you've got it.
`18 A. I'm loading now. Yes.
`19 Q. All right. And you can also see two pages from
`20 Born on your screen. So you make use of the formula
`21 from -- I mean, I guess you make use of both Equations
`22 29 and 30 from Born, Page 162, in order to do your focal
`23 length calculation for Lens 4?
`24 A. Well, in part, yes. But I think, as I recall,
`25 Born & Wolf may have a closer equation. But it is
`
` 1 related to those equations.
` 2 Q. And on the prior page, 161, Born refers to
` 3 deriving, quote, the Gaussian formula. Do you see that?
` 4 A. Yes.
` 5 Q. So these -- this formula that you use, which is
` 6 a form of the lens maker's equation, is using the
` 7 Gaussian approximation; is that right?
` 8 A. Well, it is -- it is -- formula is called the
` 9 lens maker equations. And it can be derived with the
`10 Gaussian formulas, but there is no approximation. The
`11 formula gives you the focal length. The focal length,
`12 which is a first-order property of the lens and is
`13 accurately given by the formula.
`14 DEPOSITION OFFICER: Can you repeat that.
`15 Focal length, which is a --
`16 THE WITNESS: It's a first-order property and
`17 is given accurately by the formula.
`18 DEPOSITION OFFICER: Thank you.
`19 BY MR. RUBIN:
`20 Q. So the value given by this formula -- would it
`21 be exactly identical to a focal length outputted by ray
`22 tracing software like Zemax?
`23 A. For the case of the singlet lens, yes.
`24 Q. You said, "For the case of the singlet lens"?
`25 A. Yes.
`
`Page 15
`
`Page 17
`
` 1 Q. And so that's a -- is a singlet lens -- is that
` 2 the same as a -- just a single lens element?
` 3 A. Yes.
` 4 Q. Turning back to your declaration. On Page 43
` 5 you make use of an equation from the Walker textbook. I
` 6 think in your other declaration you use a similar
` 7 formula from another textbook. But the -- so the
` 8 expression that you quote from Walker is for the
` 9 combined optical power of two lenses separated by the
`10 distance d. Do you see that?
`11 A. Yes.
`12 Q. Is this formula based on an approximation?
`13 MS. SIVINSKI: Objection. Form.
`14 THE WITNESS: The formula could be accurate
`15 if -- if applied to a single lens element if applied to
`16 thin lenses.
`17 DEPOSITION OFFICER: What type of lenses?
`18 THE WITNESS: Thin.
`19 DEPOSITION OFFICER: Thin?
`20 THE WITNESS: T-h -- to a couple of thin
`21 lenses. However, if the formula is applied to too thick
`22 lenses, may not be quite accurate. But it will give an
`23 approximation of the combined optical power as long as
`24 the thickness of the individual lenses is not too large.
`25 MR. RUBIN: Apologies. Are folks picking up
`
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`Barkley Court Reporters
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`(4) Pages 14 - 17
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`Exhibit 2003
`IPR2020-00878
`Page 4 of 48
`
`

`

`APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 18
`
`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 20
`
` 1 background noise of a squeaking dog toy?
` 2 DEPOSITION OFFICER: Yes.
` 3 MR. RUBIN: My apologies. Hopefully, it will
` 4 stop.
` 5 BY MR. RUBIN:
` 6 Q. So on Page 59 of your declaration, I think you
` 7 explain that the value of TTL being equal to
` 8 5.271 millimeters was incorrect. Do you know what the
` 9 origin of that number is? Because it seems to be close
`10 to but not the same as Ogino Example 5.
`11 A. It is verified -- what do you mean by the
`12 origin of which number?
`13 Q. Well, I guess -- yeah. I mean, is -- so there
`14 is a number 5.271 in your declaration, which you said
`15 earlier is not accurate. Is that a number that actually
`16 appears somewhere in -- in any of the references you
`17 considered or in the calculations you did, or is that
`18 merely an error in typing something into the document?
`19 A. Well, I don't recall exactly why it ended up.
`20 I -- my guess is that there were -- there was a
`21 copy-and-paste and -- and I forgot to update the number.
`22 Something like that.
`23 Q. So do you know where that number would have
`24 been pasted from?
`25 MS. SIVINSKI: Form.
`
` 1 to a lens I obtain from slightly modifying Ogino
` 2 Example 5 in view of why I stop here.
` 3 DEPOSITION OFFICER: Can you repeat those last
` 4 few words.
` 5 THE WITNESS: I stop here.
` 6 DEPOSITION OFFICER: Thank you.
` 7 BY MR. RUBIN:
` 8 Q. And on your screen you should see Exhibit 1005
` 9 from the '897 IPR Ogino. And on Page 26 of Ogino,
`10 Column 21 of the patent, there's a table labeled
`11 "Table 9." Do you see that?
`12 Do you see that?
`13 A. Yes.
`14 Q. All right. And at the bottom of the same page,
`15 Table 10 is labeled "Example 5 Aspheric Surface Data."
`16 Do you see that?
`17 A. Yes.
`18 Q. And is it correct that Tables 9 and 10 together
`19 provide the lens prescription for Ogino Example 5?
`20 A. Yes.
`21 Q. And was this lens prescription in these tables
`22 the starting point that you used in coming up with the
`23 modified examples in your declaration?
`24 A. Yes.
`25 Q. So turning back to your declaration. On
`
`Page 19
`
`Page 21
`
` 1 BY MR. RUBIN:
` 2 Q. Namely, the 5.271 number.
` 3 A. No. I -- I don't -- I don't remember. I am
` 4 right now guessing on how that number originated. I
` 5 don't remember well.
` 6 Q. So I'd like to talk about the modifications
` 7 that you performed -- or that you made to Ogino
` 8 Example 5. And maybe the best place to start would be
` 9 your appendix. So right now on the screen you should
`10 see Page 104, which was the beginning of the -- of
`11 Subsection B of your appendix Ogino Example 5 modified
`12 for f-number equal 2.8 using Zemax.
`13 Do you see that?
`14 A. Yes.
`15 Q. Now, you say, in parentheses next to the word
`16 "Zemax," V 2/14/2011. Does that indicate the particular
`17 version of Zemax that you used?
`18 A. Yes. That's correct.
`19 Q. And did you use that same version of Zemax for
`20 all of the work involving Zemax on the two IPRs we're
`21 talking about today?
`22 A. I believe so.
`23 Q. So the ray trace on Page 104 depicts a design
`24 that you obtained by Ogino Example 5; is that right?
`25 A. On the figure on Page 104, it's -- corresponds
`
` 1 Page 107 there's what's labeled "Figure 2D -
` 2 Prescription Data." Is that the lens prescription for
` 3 the first modified design that you obtained based on --
` 4 or starting with Ogino Example 5?
` 5 A. Yes. I believe so.
` 6 Q. So can you explain -- what was the process that
` 7 you followed to arrive at this lens prescription
` 8 starting with the lens prescription that's actually
` 9 given in Ogino?
`10 MS. SIVINSKI: Objection. Form.
`11 THE WITNESS: Yes. Thank you.
`12 Well, the process start with considering what a
`13 POSITA at the time will have known and considering what
`14 would be the training of that lens design of that POSITA
`15 and also planning a -- or doing a modification -- the
`16 simplest one that someone having that experience would
`17 have known.
`18 And the structure of a lens -- it's primarily
`19 determined by what is known as the first-order
`20 properties as defined by the radii of curvature and the
`21 space in between lens element and -- and the --
`22 existence of refraction. So if we can maintain the
`23 radii curvature and the spacings as given in the
`24 columns' radius thicknesses and glass, we will maintain
`25 essentially the same structure.
`
`Min-U-Script®
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`Barkley Court Reporters
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`(5) Pages 18 - 21
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`Exhibit 2003
`IPR2020-00878
`Page 5 of 48
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`

`

`APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 22
`
`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 24
`
` 1 And then we have the aspheric coefficients
` 2 that -- they have little or no bearing on what the basic
` 3 structure is, but they can help us to improve the image
` 4 quality. And the choice of aspheric coefficients --
` 5 it's very wide because there is a significant amount of
` 6 redundancy in choosing aspheric coefficients. One may
` 7 have in a single surface 2, 3, 4, 5, 7, 10, 20 aspheric
` 8 coefficients and essentially -- essentially representing
` 9 the same surface or other surfaces. So in using
`10 aspheric coefficients, there is a lot of redundancy.
`11 So to follow up after these considerations,
`12 I -- and as I recall, I decide to vary aspheric
`13 coefficients and try to maintain the first-order
`14 properties as -- as much as possible. In order to
`15 reduce the f-number and according to the teachings of
`16 Bareau, I needed to open up the aperture stop so that
`17 the f-number will be reduced so that the entrance pupil
`18 would be increased because the f-number is given by the
`19 focal length times divided by the diameter of the
`20 entrance pupil.
`21 So I change the stop diameter and re-optimize
`22 the lens using the aspheric coefficients. At some point
`23 I have to increase a little bit the thickness of the
`24 first lens to avoid a negative thickness at the edge of
`25 the first lens. And I think the end result was that
`
` 1 essentially all the radii curvature and all the spaces,
` 2 except for the slight change to the first, remain the
` 3 same, as well as the glass. And the aspheric
` 4 coefficients vary to accommodate for image quality.
` 5 I'm not sure if this answers your question.
` 6 BY MR. RUBIN:
` 7 Q. It certainly answers part of the question.
` 8 I'm -- thank you.
` 9 So comparing the prescription in Page 107 of
`10 your declaration to the prescription in Ogino -- so
`11 the -- the first column -- well, I'm sorry. The column
`12 labeled "Radius" -- do you believe that all the numbers
`13 in that column are the same as the corresponding radii
`14 in Ogino Example 5?
`15 A. As I recall, I believe so. But I will have to
`16 double-check just to be accurate.
`17 Q. Okay. I guess can -- are you able to pull up
`18 Ogino Example 5 on your screen and compare it --
`19 A. Okay. Just a second.
`20 Q. -- to your declaration?
`21 A. I have to first be able -- the first radius
`22 reads on my declaration 1.12444, and in the patent I
`23 think it reads the same. The second radius is
`24 252097584, and on the patent '897 it reads the same.
`25 The third radius where the stop is located reads --
`
` 1 Q. Sorry. Professor Sasian, if I can cut you off.
` 2 I don't think we need to read through all of them; but I
` 3 guess just as far as you know, there is no difference in
` 4 the radii and curvature?
` 5 A. Yeah.
` 6 Q. Now, for the next column in your prescription
` 7 data it looks to me like there are at least two changes.
` 8 So the thickness in the row labeled "1" in your
` 9 declaration, the prescription data is listed as .6
`10 whereas the thickness in Row 1 in Ogino Example 5 is
`11 listed as .546.
`12 Do you agree there's a difference there?
`13 A. Yes.
`14 Q. And did I understand your testimony earlier to
`15 be that you made the thickness of the first lens element
`16 greater in order to permit the diameter of the lens
`17 element to be larger?
`18 A. Not exactly. The thickness of the first
`19 element was made thicker to avoid a negative thickness
`20 at the edge of the lens.
`21 Q. Okay. And was .6 a number that you entered by
`22 hand, or was that the result of a -- a solve performed
`23 using Zemax?
`24 MS. SIVINSKI: Objection. Form.
`25 THE WITNESS: I likely entered it by hand.
`
`Page 23
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`Page 25
`
` 1 BY MR. RUBIN:
` 2 Q. And is that reflected in the fact that there is
` 3 no letter to the right of the value in your screen
` 4 capture from Ogino -- your screen capture from Zemax, I
` 5 mean?
` 6 A. No. It's more reflected by the fact that there
` 7 is only one digit.
` 8 Q. I see. So it could have been the result of a
` 9 solve using Zemax. It wouldn't be such a round number?
`10 A. Correct.
`11 Q. And then the other difference that I see in the
`12 thickness column is in Line 13, where in your
`13 modification the thickness is 1.464, approximately, and
`14 in Ogino Example 5 it's 1.74. Do you agree?
`15 A. Yes.
`16 Q. And I -- was the -- the thickness in your
`17 modified design the result of a solve using Zemax?
`18 MS. SIVINSKI: Objection. Form.
`19 THE WITNESS: Yes.
`20 BY MR. RUBIN:
`21 Q. All right. And briefly, what is -- what is a
`22 solve in the context of a Zemax software?
`23 A. A solve is a calculating aid that the problem
`24 performs, in this case to determine what is the distance
`25 from the last surface of the lens to the image plane
`
`Min-U-Script®
`
`Barkley Court Reporters
`
`(6) Pages 22 - 25
`
`Exhibit 2003
`IPR2020-00878
`Page 6 of 48
`
`

`

`APPLE, INC. v.
`COREPHOTONICS, LTD.
`
`Page 26
`
`JOSE SASIAN, Ph.D.
`January 22, 2021
`Page 28
`
` 1 according to first-order optics.
` 2 DEPOSITION OFFICER: According to what?
` 3 THE WITNESS: First-order optics.
` 4 BY MR. RUBIN:
` 5 Q. Is the fact that the -- withdrawn.
` 6 So the distance -- distance 13 in this lens
` 7 prescription is the distance between the cover glass and
` 8 the image sensor; is that right?
` 9 A. Between the second surface of the cover glass
`10 and the image plane or the sensor.
`11 Q. And do you have an understanding of why the
`12 Zemax solve found that the -- that distance should be
`13 shorter than the distance provided in Ogino for
`14 Example 5?
`15 MS. SIVINSKI: Objection. Form.
`16 THE WITNESS: Can you please repeat the
`17 question.
`18 BY MR. RUBIN:
`19 Q. One moment.
`20 My question was, Do you have an understanding
`21 of why the Zemax solve found that that distance -- and I
`22 was referring to the thickness of Row 13 -- should be
`23 shorter than the distance provided in Ogino for
`24 Example 5?
`25 MS. SIVINSKI: Objection. Form.
`
` 1 elements?
` 2 A. Yes, it does.
` 3 Q. And are you aware of any differences between
` 4 the indices of refraction and Abbe numbers in your
` 5 modified lens and those values provided in Ogino
` 6 Example 5?
` 7 A. No, I'm not aware.
` 8 Q. Do you see to the right of certain entries in
` 9 the glass column there's the capital letter T?
`10 A. Yes.
`11 Q. What does that indicate?
`12 A. That indicates that that particular glass is
`13 going to be pick up from a previous one. To be more
`14 accurate, the -- let me -- well, actually, I cannot see
`15 very well the Page 107. If you could increase the size.
`16 Q. Is that -- sorry. Is that better?
`17 A.