UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ----------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` ----------
`
` APPLE INC,
`
` Petitioner,
`
` vs.
`
` COREPHOTONICS, LTD.,
`
` Patent Owner.
`
` ----------
`
` Case No. IPR2020-00877
`
` U.S. Patent No. 10,288,840
`
` Case No. IPR2020-00878
`
` U.S. Patent No. 10,330,897
`
` Case No. IPR2020-00906
`
` U.S. Patent No. 10,225,479
`
` Deposition of JOSÉ SASIÁN, Ph.D.
`
` Friday, May 28, 2021
`
`Reported by:
`
`Pamela Harrison
`
`Job No.: 2407
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 1 of 159
`
`
`
` ----------
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` ----------
`
` APPLE INC,
`
` Petitioner,
`
` vs.
`
` COREPHOTONICS, LTD.,
`
` Patent Owner.
`
` ----------
`
` Case No. IPR2020-00877
`
` U.S. Patent No. 10,288,840
`
` Case No. IPR2020-00878
`
` U.S. Patent No. 10,330,897
`
` Case No. IPR2020-00906
`
` U.S. Patent No. 10,225,479
`
` Deposition of JOSÉ SASIÁN, Ph.D.
`
` Friday, May 28, 2021
`
`Reported by:
`
`Pamela Harrison
`
`Job No.: 2407
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 1 of 159
`
`
`
`Page 2
`
` VIDEO RECORDED VIDEOCONFERENCE
`
`DEPOSITION OF JOSÉ SASIÁN, PhD, located in Tucson,
`
`Arizona, taken on behalf of Patent Owner
`
`Corephotonics, Ltd., on the 28th day of May 2021,
`
`before Pamela Harrison, RPR, CRR, CRC,
`
`MO-CCR #557, IL-CSR #084-003684.
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 2 of 159
`
`
`
`Page 3
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` A P P E A R A N C E S:
`
`FOR THE PETITIONER: (Via remote)
`
` STEPHANIE SIVINSKI, ESQ.
`
` MICHAEL S. PARSON, ESQ.
`
` JORDAN MAUCOTEL, ESQ.
`
` Haynes and Boone, LLP
`
` 2323 Victory Avenue, Suite 700
`
` Dallas, TX 75219
`
` 214.651.5078
`
` stephanie.sivinski@haynesboone.com
`
` michael.parsons.ipr@haynesboone.com
`
` jordan.maucotel.ipr@haynesboone.com
`
`FOR THE PATENT OWNER: (Via remote)
`
` NEIL RUBIN, ESQ.
`
` Russ August & Kabat
`
` 12424 Wilshire Blvd., 12th Floor
`
` Los Angeles, CA 90025
`
` 310.826.7474
`
` Nrubin@raklaw.com
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`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 3 of 159
`
`
`
`Page 4
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` A P P E A R A N C E S:
`
`
`
`
`
`THE VIDEOGRAPHER: (Via remote)
`
` KEVIN CROWLEY
`
` _ _ _ _ _ _ _ _
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 4 of 159
`
`
`
`Page 5
`
` I N D E X
` JOSÉ SASIÁN, PHD
` May 28, 2021
`
` APPEARANCES 3
`
`EXAMINATION OF JOSÉ SASIÁN, PHD:
`
` Questions by Mr. Rubin 10
`
` CERTIFICATE 138
`
` ACKNOWLEDGMENT OF DEPONENT 139
`
` ERRATA 140
`
` LAWYER'S NOTES 141
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`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 5 of 159
`
`
`
`Page 6
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` DEPOSITION EXHIBITS
` JOSÉ SASIÁN, PHD
` May 28, 2021
`
` NUMBER DESCRIPTION MARKED
`
` (No exhibits proffered.)
`
` PREVIOUSLY MARKED EXHIBITS
`
` NUMBER DESCRIPTION MARKED
`
` 1001 US Patent Number 10,330,897 B2 86
`
` 1003 Declaration of José Sasián, 42
` Ph.D. under 37 C.F.R. § 1.68,
` APPL-1003 ('840 patent)
`
` Declaration of José Sasián, 95
` Ph.D. under 37 C.F.R. § 1.68
` ('897 patent)
`
` 1005 US Patent 7,859,588 B2 65
`
` US Patent Number 9,128.267 B2, 127
` APPL-1005
`
` 1011 Patent Number 7,561,191 17
`
` 1012 English translation of the 62
` Kawamura patent, APPL-1012
`
` 1013 Declaration of José Sasián, 51
` PhD, under 37 C.F.R. § 1.68 in
` Support of Petitioner’s Reply,
` APPL-1013
`
` 1015 Translated version of Japanese 108
` Patent 2013-106289, APPL-1015
`
` 1021 Declaration of José Sasián, 48
` PhD, under 37 C.F.R. § 1.68 in
` Support of Petition
` for Inter Partes Review,
` APPL-1021
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 6 of 159
`
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` PREVIOUSLY MARKED EXHIBITS
`
` NUMBER DESCRIPTION MARKED
`
` 1022 Declaration of José Sasián, 14
` PhD, under 37 C.F.R. § 1.68
` in Support of Petitioner
` Reply, APPL-1022 /
` IPR2020-00877
`
` 1026 US Patent 5,546,236, APPL-1026 67
`
` 1035 Japanese Patent 201, 3-106289, 108
` APPL-1035
`
` 1036 US Patent 9,223,118 B2, 116
` APPL-1036
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` 1037 Declaration of José Sasián, 16
` PhD, under 37 C.F.R. § 1.68
` in Support of Petitioner
` Reply, APPL-1037 /
` IPR2020-0087
`
` 1039 Declaration of José Sasián, 16
` PhD, under 37 C.F.R. § 1.68 in
` Support of Petitioner’s Reply,
` APPL-1039
`
` 2004 Excerpts from "Introduction to 119
` Lens Design"
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 7 of 159
`
`
`
` (On the record at 9:09 a.m.
`
` Pacific Time.)
`
`Page 8
`
` THE VIDEOGRAPHER: Good morning. We are
`
`on the record. Today's date is May 28, 2021. The
`
`time is 9:09 a.m. Pacific Time.
`
` This is the video-recorded deposition of
`
`Dr. José Sasián in the matter of Apple
`
`Incorporated versus Corephotonics, Limited. This
`
`is in the United States Patent and Trademark
`
`Office, Case Numbers IPR2020-00877, IPR2020-00878,
`
`and IPR2020-00906.
`
` This deposition is taking place via web
`
`videoconference with all attendants --
`
`participants attending remotely. The videographer
`
`is Kevin Crowley, representing TransPerfect. The
`
`court reporter is Pamela Harrison.
`
` Counsel, could you please identify
`
`yourselves and whom you represent, beginning with
`
`the questioning attorney, followed by the reporter
`
`swearing in the witness. Thank you.
`
` MR. RUBIN: Good morning. This is Neil
`
`Rubin of Russ August & Kabat representing the
`
`patent owner, Corephotonics, Limited.
`
` MS. SIVINSKI: Good morning. Stephanie
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 8 of 159
`
`
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`Page 9
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`Sivinski with Haynes and Boone. I represent Apple
`
`Inc., the petitioner. And with me today are my
`
`colleagues Michael Parsons and Jordan Maucotel,
`
`also with Haynes and Boone.
`
` THE REPORTER: Will counsel please
`
`stipulate that in lieu of formally swearing in the
`
`witness, I will instead ask the witness to
`
`acknowledge that his testimony will be true under
`
`the penalties of perjury, that counsel will not
`
`object to the admissibility of the transcript
`
`based on proceeding in this way, and that the
`
`witness has verified that he is, in fact, José
`
`Sasián?
`
` Counsel?
`
` MS. SIVINSKI: We will stipulate.
`
` MR. RUBIN: And we will stipulate as
`
`well.
`
` THE REPORTER: Doctor, would you please
`
`raise your right hand.
`
` Do you hereby acknowledge that your
`
`testimony will be true under the penalties of
`
`perjury?
`
` THE WITNESS: Yes.
`
` THE REPORTER: Thank you.
`
` Counsel, you may proceed.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 9 of 159
`
`
`
` JOSÉ SASIÁN,
`
`Page 10
`
`of lawful age, having been first duly sworn to
`
`testify the truth, the whole truth, and nothing
`
`but the truth says in reply to oral
`
`interrogatories propounded as follows, to wit:
`
` EXAMINATION
`
`QUESTIONS BY MR. RUBIN:
`
` Q. Good morning, Mr. Sasián.
`
` A. Good morning, Mr. Rubin.
`
` Q. So you've been deposed a number of times
`
`before; is that right?
`
` A. Yes.
`
` Q. And at least one of those depositions in
`
`the past couple of months was taken by me and was
`
`done over Zoom, correct?
`
` A. Yes.
`
` Q. All right. And so you're familiar with
`
`the deposition process; is that right?
`
` A. I have some familiarity with it.
`
` Q. And you're familiar with the Zoom
`
`software and comfortable being deposed over Zoom?
`
` A. Yes.
`
` Q. As comfortable as anyone is in a
`
`deposition, I suppose.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 10 of 159
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`Page 11
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` So you are aware that, under the rules
`
`governing the deposition today, you're not allowed
`
`to, at any point during my questioning, discuss
`
`your testimony or my questions with anyone else;
`
`do you understand that?
`
` A. Yes.
`
` MS. SIVINSKI: Just to clarify, issues
`
`about attorney-client privilege are an exception
`
`to that rule.
`
` Go ahead.
`
` A. Yes, I am aware of.
`
`QUESTIONS BY MR. RUBIN:
`
` Q. And so you understand you're not allowed
`
`to communicate with anyone, for example, through
`
`your computer or phone or anything like that,
`
`while we're on the record, correct?
`
` A. As I understand, to communicate
`
`regarding what is happening in this deposition.
`
`Though if in the break time I check my email, is
`
`that okay?
`
` Q. So I have no problem with you checking
`
`your email during the break as long as that email
`
`has nothing to do with the deposition.
`
` Is that all right?
`
` A. Yes. Thank you.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 11 of 159
`
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`Page 12
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` Q. All right. And so during breaks, you
`
`won't discuss with Apple's counsel or with anyone
`
`else your testimony or my questions or questions
`
`that I may ask in the future. And again, I'm
`
`referring to breaks in my questioning; that is,
`
`before Apple's attorneys have their chance to ask
`
`their questions.
`
` Do you understand that?
`
` A. Well, so there are two types of breaks:
`
`one is when the record stops, and another when we
`
`are -- you are asking and I am answering. I
`
`started to get confused, then.
`
` Q. All right. So let me -- let me try to
`
`make this a little bit simpler.
`
` So when we take a break while I'm still
`
`asking you questions and we go off the record, you
`
`agree that during those breaks we're off the
`
`record, you're not going to discuss with Apple's
`
`counsel or anyone else your testimony, my
`
`questions, or questions that you expect I might
`
`ask?
`
` A. Yes. I agree with that.
`
` Q. All right. Thank you.
`
` Is there any reason that you're aware of
`
`today that you can't give your full and complete
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 12 of 159
`
`
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`Page 13
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`testimony on the subjects of this deposition?
`
` A. At this moment, I don't have any reason
`
`not to do so.
`
` Q. Okay. So you're not suffering from any
`
`illness or taking any medication that would affect
`
`your memory or your ability to understand and
`
`answer questions?
`
` A. No.
`
` Q. All right. And you're -- well, let me
`
`step back.
`
` Do you have any questions about the
`
`deposition process before we proceed?
`
` A. No. I think -- I believe I understand
`
`to a good extent what is expected from me. And,
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`yes, I will follow your guidelines.
`
` Q. And do you have any notes or other
`
`documents with you today that you might consult in
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`answering my questions?
`
` A. No. Here on this table, I don't think I
`
`have any document related to the deposition. And
`
`in the computer, there are folders with my
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`declarations and supporting documents, but I will
`
`not touch those unless you direct me to do so.
`
` Q. Okay.
`
` A. I have created a folder to download the
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 13 of 159
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`Page 14
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`exhibits for today, and I will only access that
`
`folder unless you direct me to otherwise.
`
` Q. Okay. So using the chat function in
`
`Zoom, I've uploaded -- I've actually uploaded five
`
`documents so far. The first two are deposition
`
`notices, which you don't need to download, unless
`
`you'd like to. But I would like you right now to
`
`download the last three documents.
`
` A. Okay. I have them now.
`
` Q. So you should see on your screen now one
`
`of those documents, which is Exhibit 1022 from
`
`IPR2020-00877; do you see that?
`
` A. Yes.
`
` Q. Okay. So as you know, there are three
`
`IPRs that you've submitted reply declarations in
`
`that are the subject of today's deposition. Those
`
`are IPR2020-00877, -00878, and -00906.
`
` And you submitted a declaration in each
`
`one of those three IPRs; is that right?
`
` A. I don't recall the -- or I don't go by
`
`the numbers you mentioned. I recall the documents
`
`I submitted as related to the '897, '840, and
`
`'470, and '479 patents.
`
` Q. Okay. Okay. Well, I will -- I will try
`
`to make it -- so I probably for the -- to make the
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 14 of 159
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`record clear, I'll probably, when I'm introducing
`
`exhibits, identify the IPR that they were
`
`introduced in using the last three digits of the
`
`IPR number. So that would be 877, 878, and 906.
`
` Just so you know, the reason I'm doing
`
`that is, if I use the patent numbers, there are
`
`actually two IPRs that have been filed against the
`
`'479 patent. So if I just use the patent number,
`
`there might be some ambiguity. But I will also
`
`try to make it clear which patent the IPR that
`
`we're talking about refers to -- or relates to by
`
`using the patent number '840, '897 or '479.
`
`Hopefully, that won't be confusing. If at any
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`point you are confused about what proceeding a
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`document comes from, let me know, okay?
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` A. Thank you.
`
` Q. So in front of us on the screen is your
`
`declaration from the 00877 IPR, which concerns the
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`'840 patent, okay?
`
` A. Yes.
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` Q. And to be clear, this is your reply
`
`declaration or your declaration in support of
`
`Apple's reply, okay?
`
` All right. So then the -- another
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`document that I've uploaded in the chat function
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 15 of 159
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`is Exhibit 1037 from the 00878 IPR, which is the
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`IPR concerning the '897 patent, okay?
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` And then on the screen now is
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`Exhibit 1039 from IPR-00906, which is one of the
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`IPRs concerning the '479 patent.
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` Do you see that?
`
` A. Yes.
`
` I should remind that occasionally, the
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`internet may go here for maybe for seconds.
`
`Please work with me, and I'll be back, just in
`
`case the internet stops here briefly.
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` Q. Okay. Have you had problems with the
`
`internet since we've been on the record, or was
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`there anything that you missed?
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` A. No. No.
`
` Q. Okay.
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` A. I haven't had any problems in the last
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`few days, but it could happen, and I wanted you to
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`be aware of.
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` Q. Okay. So the three declarations that
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`we've just looked at, at least the first page of
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`each, are you aware of any errors in any of these
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`declarations, sitting here today?
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` A. There might be a clerical error on the
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`IPR-878 regarding a reference to Dr. Milster
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 16 of 159
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`deposition transcript.
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` Q. Do you recall where in that declaration
`
`that error was?
`
` A. I think it's paragraph 18.
`
` Q. Is this the paragraph you had in mind?
`
`You can feel free to look at your copy of the
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`document if that helps.
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` A. Okay. Let me open it.
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` Actually, it's paragraph 21.
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` Q. Okay.
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` A. The last reference in that paragraph
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`appears to be incorrect.
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` Q. Okay. Do you know what the correct
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`citation to Dr. Milster would be?
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` A. Not at this moment.
`
` Q. Okay. So I'd like to turn to your
`
`declaration from the 877 IPR concerning the '840
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`patent.
`
` So -- all right. So I've just uploaded,
`
`using the chat function, a copy of Exhibit 1001
`
`from the 877 IPR, which is the patent to May, et
`
`al., US Patent Number 7,561,191.
`
` Do you see that on the screen?
`
` A. Yes.
`
` Q. And you recall offering opinions about
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 17 of 159
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`this patent, right?
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` A. Yes.
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` MS. SIVINSKI: Neil, just so the record
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`is clear, I think this is Exhibit 1011, not 1001.
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` MR. RUBIN: That's exactly right, and I
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`misspoke. So I meant to say Exhibit 1011.
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`QUESTIONS BY MR. RUBIN:
`
` Q. Okay. So see on -- at the bottom of
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`Column 11, in May, starting at line 66, it says
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`"In a preferred embodiment, the image sensors 12
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`and 14 are single-chip color Megapixel CCD
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`sensors, using the well-known Bayer color filter
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`pattern to capture color images."
`
` Do you see that?
`
` A. Could you please say again the column
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`and lines?
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` Q. So what I read is from Column 11,
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`line 66, through Column 12, line 1.
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` A. Would you please move a little bit up
`
`the document? Okay.
`
` Q. Does that help?
`
` A. Yeah, it helps on the Column 11.
`
` Q. And really, what I'm -- what I'm going
`
`to ask you about is just the portion of the
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`sentence in Column 11 which says "the image
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
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`sensors 12 and 14 are single-chip color Megapixel
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`CCD sensors."
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` Do you see that?
`
` Okay. So would you agree that CCD
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`sensors are generally fabricated on a silicon
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`chip?
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` A. They can be fabricated in a silicon
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`chip, yes, in a silicon wafer.
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` Q. All right. And are you aware of any
`
`other way that CCDs are made other than as silicon
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`chips in a silicon wafer?
`
` Let me withdraw that question and ask
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`another question.
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` Are you aware of any other way that
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`megapixel CCD sensors are made other than as
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`silicon chips fabricated on a silicon wafer?
`
` A. It might be possible to fabricate them
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`in other type of substrates, semiconductor
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`substrates.
`
` Q. So when you say "other types of
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`semiconductor substrates," you're saying
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`semiconductors other than silicon?
`
` A. Yes.
`
` Q. Are you aware of any examples of a
`
`megapixel CCD sensor that is made some other way
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
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`than in a semiconductor chip fabricated in a
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`semiconductor wafer?
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` A. Other than silicon?
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` Q. So my question was -- so I take it that
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`CCDs can be made as semiconductor chips on
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`semiconductor wafers.
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` And my question is whether there's
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`any -- whether you're aware of megapixel CCDs ever
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`being made any way other than as semiconductor
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`chips on semiconductor wafers?
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` A. I don't understand the question. Could
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`you please rephrase it?
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` Q. Okay. So earlier, I asked a question
`
`about silicon wafers and silicon chips. And you
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`pointed out in your answer that, well, you might
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`make a CCD using some semiconductor other than
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`silicon.
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` So now I'm -- I'm asking a question
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`that's not limited to silicon; it can be any sort
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`of semiconductor. But my question is: Would you
`
`agree that megapixel CCD sensors are made as
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`semiconductor chips on semiconductor wafers?
`
` A. Yes.
`
` Q. Are you aware of any way of making a
`
`megapixel CCD that does not involve making it as a
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`Apple v. Corephotonics, IPR2020-00878
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`semiconductor chip on a semiconductor wafer?
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` A. Not at this moment.
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` Q. All right. Now, the May patent also
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`gives CMOS sensors as an example of a sensor one
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`could use.
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` Would you agree that CMOS sensors are
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`also made as semiconductor chips fabricated on
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`semiconductor wafers?
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` A. Yes.
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` Q. Now, you would agree that a
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`semiconductor chip is not a printed circuit board,
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`correct?
`
` A. Yes, I agree.
`
` Q. So when May says that Sensors 12 and 14
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`are single-chip CCD sensors, it's not saying that
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`12 or 14 are printed circuit boards, correct?
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` A. It is not saying that the CCD or CMOS
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`sensors' chips are printed circuit boards; but
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`being an electronic component, it has to be
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`mounted. And it would be mounted on a printed
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`circuit board because either sensor, the CCD or
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`the CMOS, has many electrical terminals, and those
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`would be registered with a printed circuit board
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`that would be miniature in size because of the
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`miniature size of the sensor chip -- or not
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`Apple v. Corephotonics, IPR2020-00878
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`miniature size. It can be larger. But given the
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`plurality of electrical connections that such
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`sensors carry, they need to be mounted on -- I am
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`unaware that such chips are not mounted on a
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`printed circuit board.
`
` (Reporter clarification.)
`
`QUESTIONS BY MR. RUBIN:
`
` Q. So is it your -- withdrawn.
`
` Are you saying that it's impossible to
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`use a semiconductor chip without mounting it on a
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`printed circuit board?
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` A. No, I'm not saying that it's impossible.
`
`But in my experience -- I'm recalling, for
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`example, both the Parulski reference and the Ryu
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`reference that show such a chip mounted on a PC
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`board that gives examples of how such a chip is
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`mounted on a circuit board. And I have
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`disassembled camera assemblies, and the
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`semiconductor chip is mounted on a little circuit
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`board to make the connections and perhaps add some
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`other electronic components.
`
` Q. So on your screen now, you should see
`
`Figures 24A and 24B from the May patent,
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`Exhibit 1011.
`
` Do you see that?
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`Apple v. Corephotonics, IPR2020-00878
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` A. Yes.
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` Q. And these figures show us what the
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`patent calls a substrate element 620.
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` Do you see that?
`
` A. Yes.
`
` Q. And it's your opinion that that
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`substrate is a printed circuit board; is that
`
`right?
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` A. Could you please send to me that
`
`reference to review it, please?
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` Q. Yes. So it's already in the chat
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`function. You can go ahead and download it if
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`you'd like.
`
` A. Okay. Just a second, please.
`
` I am having a little bit of problem
`
`here. Just a second.
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` Okay. I am trying to get there, but I'm
`
`having somehow a problem.
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` MS. SIVINSKI: Do you want to go off the
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`record so you can find the record?
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`QUESTIONS BY MR. RUBIN:
`
` Q. Do you have a copy of this on your local
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`computer? Is this one of the files that you --
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` A. I have downloaded -- I have downloaded,
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`but the problem is that somehow, I couldn't access
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`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
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`the folder. So let me -- okay. And now I am
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`opening the patent.
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` It's open now. And let me scroll down.
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`Okay.
`
` On Column 23, line about 48, it reads
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`"Each lens 612 and 616 and each associated image
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`sensor 614 and 618 are mounted to the
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`substrate 620 with an IR cut filter."
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` Then in the next sentence, it says
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`"Electronic components 624, such as resistors,
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`capacitors and power management components, are
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`also mounted on the substrate 620. The image
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`signals are taken from the substrate 620 via a
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`flex connector 626."
`
` And if we go to the original Figure 24,
`
`the statements that I just read point out that
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`such substrate is the -- it's a printed circuit
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`board, because it's where electronic components
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`are mounted and because there is a flex connector
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`to carry the electrical signals.
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` So I believe -- I believe that -- or I
`
`should say in this way, May is disclosing a
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`printed circuit board.
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`QUESTIONS BY MR. RUBIN:
`
` Q. Okay. So the substrate 620 in May you
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`Apple v. Corephotonics, IPR2020-00878
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`believe is a printed circuit board because the
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`sensor is mounted on it and -- the sensors are
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`mounted on it and other electronic components are
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`also mounted on it; is that -- am I understanding
`
`that correctly?
`
` A. In addition, the flex cable that clearly
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`identifies it as the connector for the electrical
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`signals.
`
` Q. All right. Now, the embodiments in
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`May's Figure 10, which show folded lenses, or
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`embodiments that contain folded lenses, none of
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`those embodiments is shown as having a substrate
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`that the sensor is mounted on; would you agree?
`
` A. Well, I don't agree that -- well, it's
`
`not clear to me that those components are
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`folded -- are folded lenses.
`
` Q. Okay. But the embodiments that are
`
`shown in the various examples of Figure 10 have
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`sensors which are labeled 12 or 14 or 16; would
`
`you agree?
`
` A. I would call them camera assemblies.
`
` Q. Okay. But in Figure 10A, for example,
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`Element 12 is the sensor; is that right?
`
` A. Well, it could be.
`
` Q. Okay. So let's turn to Column 7.
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`Starting at line 16, it says "In a first
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`embodiment, a digital camera employs a first fixed
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`focal length wide angle lens 2 with a first image
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`sensor 12, and a zoom lens 3 with a second image
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`sensor 14."
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` Do you see that?
`
` A. Yes.
`
` Q. And then starting at line 36, it says,
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`"In a second embodiment, a digital camera employs
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`a first zoom lens 3 with an image sensor 14, and a
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`second zoom lens 4 with an image sensor 16."
`
` Do you see that?
`
` A. Yes.
`
` Q. So turning back to Figure 10, you'd
`
`agree that the elements labeled here -- 12, 14,
`
`and 16 -- are image sensors, right?
`
` A. Could you please tell me what are the
`
`columns in May that refer to those elements so
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`that I can read them here on my copy of May?
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` Q. Sure. What I just read from May was in
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`Column 7, and specifically lines 16 through 18,
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`and lines 36 through 38.
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` A. Thank you. Let me go through them.
`
` Could you please repeat the question?
`
` Q. So my question was: In Figure 10, you'd
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`Apple v. Corephotonics, IPR2020-00878
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`agree that the elements labeled 12, 14, and 16 are
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`image sensors, correct?
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` A. I need to review my 877 declaration so I
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`have it in front of me.
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` Q. Are you asking for a copy of it or --
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` A. No.
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` Q. -- you're asking for your reply
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`declaration or the original declaration?
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` A. It's my reply declaration --
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` Q. Okay.
`
` A. -- that you put in the chat function and
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`that I downloaded earlier today, meaning the
`
`beginning of the deposition.
`
` Q. Are you asking me permission to review?
`
` A. Yes.
`
` Q. You can review.
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` A. Thank you.
`
` Q. Yeah. I guess, just generally, you can
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`feel free to review any of the documents that I've
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`shared in the chat function without asking
`
`permission. If you'd just let me know that you're
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`reviewing it, that --
`
` A. Thank you.
`
` Q. -- would be helpful.
`
` A. To answer your question, I bring
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`Apple v. Corephotonics, IPR2020-00878
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`attention to Figure 24, 24A, that shows the
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`printed circuit board and the flex connector.
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` Q. Okay. So my question was whether the --
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`withdrawn.
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` A. I think --
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` Q. I asked you some questions about
`
`Figure 24 a few minutes ago, but now I'm asking
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`questions about Figure 10 and the embodiment
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`that's shown in Figure 10.
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` A. Yeah. What happened is that I didn't
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`finish answering.
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` Q. Okay.
`
` A. I was --
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` Q. Please go ahead.
`
` A. I was answering.
`
` So to answer your question, I was saying
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`that I bring attention to Figure 24A where
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`previously I said that substrate 620 would be
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`understood as a printed circuit board, and then
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`with the flex connector 626, in view of this
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`figure that shows that something -- it's extended
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`from the position of the lenses.
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` The Figures 10, 10D, 10E, 10F that you
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`brought in asking your question on whether the --
`
`the particular figures' features, let me bring the
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`Corephotonics Exhibit 2012
`Apple v. Corephotonics, IPR2020-00878
`Page 28 of 159
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`Page 29
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`numbers on those figures. I think you mentioned
`
`Items 12, 14 -- 14, 16.
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` So in consideration of Figure 24A that
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`shows extending parts, the answer to your question
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`is that Elements 12, 14, 16 could be the image
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`sensors, but they also -- the image sensors could
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`be also located beneath the Lenses 2 and 3. I
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`think that is my understanding.
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` Q. All right. So I'd like to turn back
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