1 UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________
` 2
` BEFORE THE PATENT TRIAL AND APPEALS BOARD
` 3 _______________
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` 4 APPLE INC.,
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` 5 Petitioner,
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` 6 v.
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` 7 COREPHOTONICS, LTD.,
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` 8 Patent Owner.
` _______________
` 9
` Case No. IPR2020-00489
` 10
` U.S. Patent No. 10,015,408
` 11 _______________
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` 12
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` 13
`
` 14 DEPOSITION OF JOS… SASI¡N, Ph.D., taken on
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` 15 behalf of the patent owner, via videoconference,
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` 16 commencing at 9:04 a.m., Tuesday, November 10, 2020,
`
` 17 before Diana L. Porter, Certified Shorthand Reporter
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` 18 No. 12729.
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`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 1
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` _______________
` 2
` BEFORE THE PATENT TRIAL AND APPEALS BOARD
` 3 _______________
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` 4 APPLE INC.,
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` 5 Petitioner,
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` 6 v.
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` 7 COREPHOTONICS, LTD.,
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` 8 Patent Owner.
` _______________
` 9
` Case No. IPR2020-00489
` 10
` U.S. Patent No. 10,015,408
` 11 _______________
`
` 12
`
` 13
`
` 14 DEPOSITION OF JOS… SASI¡N, Ph.D., taken on
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` 15 behalf of the patent owner, via videoconference,
`
` 16 commencing at 9:04 a.m., Tuesday, November 10, 2020,
`
` 17 before Diana L. Porter, Certified Shorthand Reporter
`
` 18 No. 12729.
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` 19
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`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 1
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`1 APPEARANCES:
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`2 FOR PATENT OWNER:
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`3
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`4
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`5
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`6
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`RUSS, AUGUST & KABAT
`BY: NEIL A. RUBIN, ESQ.
`12424 Wilshire Boulevard
`12th Floor
`Los Angeles, California 90025
`(310)826-7474
`nrubin@raklaw.com
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`7 FOR PETITIONER:
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`8
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`9
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`10
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`HAYNES AND BOONE, LLP
`BY: DAVID W. O'BRIEN, ESQ.
`HONG SHI, ESQ.
`600 Congress Avenue
`Suite 1300
`Austin, Texas 78701
`david.obrien.ipr@haynesboone.com
`hong.shi.ipr@haynesboone.com
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`13 ALSO PRESENT:
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`RANDY A. YOUNG, VIDEOGRAPHER
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`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 2
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` 1 INDEX TO EXAMINATION
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` 2
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` 3 EXAMINATION PAGE
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` 4 By Mr. Rubin ..........................................8
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`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 3
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`
`
` 1 INDEX TO EXHIBITS
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` 2
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` 3 EXHIBIT DESCRIPTION PAGE
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` 4 EXHIBIT 1003 Declaration of Dr. Sasi·n 9
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` 5 EXHIBIT 1005 Golan patent application 48
` publication
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` EXHIBIT 1007 English translation of the Kawamura 35
` 7 Japanese patent application
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` 8 EXHIBIT 2002 Cover of book 52
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`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 4
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` 1 VIDEOCONFERENCE, CALIFORNIA; TUESDAY, NOVEMBER 10, 2020
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` 2 9:04 A.M.
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` 3
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` 4 THE VIDEOGRAPHER: This marks the beginning 09:04
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` 5 of Media Number 1 of Volume I of the virtual Zoom 09:04
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` 6 deposition of Dr. JosÈ Sasi·n, taken on behalf of 09:04
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` 7 the attorneys for the patent owner in the matter of 09:04
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` 8 Apple Inc., Petitioner, versus Corephotonics Ltd., 09:04
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` 9 Patent Owner, Cause Number IPR2020-00489, U.S. 09:04
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` 10 Patent Number 10,015,408, in United States Patent 09:04
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` 11 and Trademark Office, before the Patent Trial and 09:04
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` 12 Appeal Board. 09:05
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` 13 This deposition is being held -- held 09:05
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` 14 remotely via Zoom on November [10th], 2020. The 09:05
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` 15 video operator today is Randy A. Young, and the 09:05
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` 16 court reporter is Diana Porter, who are on behalf of 09:05
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` 17 Barkley Court Reporting, whose office is located at 09:05
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` 18 10350 Santa Monica Boulevard in Los Angeles, 09:05
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` 19 California. 09:05
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` 20 We are going on the record now, and the 09:05
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` 21 time is approximately 9:05 a.m. 09:05
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` 22 Will counsel please state their appearance 09:05
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` 23 for the record and state whom you represent. 09:05
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` 24 MR. RUBIN: This is Neil Rubin of Russ 09:05
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` 25 August & Kabat, representing Patent Owner, 09:05
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` 6
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 5
`
`
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` 1 Corephotonics Ltd. 09:05
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` 2 MS. SHI: Hong Shi from Haynes and Boone, 09:05
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` 3 representing petitioner and the witness. With me is 09:05
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` 4 David O'Brien, also from Haynes and Boone, 09:06
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` 5 representing petitioner and the witness. 09:06
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` 6 THE VIDEOGRAPHER: Thank you. If there are 09:06
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` 7 no stipulations, will the court reporter please 09:06
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` 8 swear in the witness. 09:06
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` 9 (JOS… SASI¡N, Ph.D., deponent, was 09:06
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` 10 sworn and examined and testified as 09:06
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` 11 follows:) 09:06
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` 12 THE DEPOSITION OFFICER: Please raise your 09:06
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` 13 right hand, Doctor. You do solemnly state, under 09:06
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` 14 penalty of perjury, that the evidence you shall give 09:06
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` 15 in this matter shall be the truth, the whole truth, 09:06
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` 16 and nothing but the truth? 09:06
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` 17 THE DEPONENT: Yes. 09:06
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` 18 CERTIFIED SHORTHAND REPORTER: And I will 09:06
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` 19 note for the record that the date is November 10th, 09:06
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` 20 not November 9th. 09:06
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` 21 And, Counsel, you can proceed. 09:06
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` 22 THE VIDEOGRAPHER: Thank you. 09:06
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` 23 MR. RUBIN: Thank you. 09:06
`
` 24 ///
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` 25 ///
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` 7
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 6
`
`
`
` 1 EXAMINATION 09:06
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` 2 BY MR. RUBIN: 09:06
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` 3 Q Good morning. 09:06
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` 4 A Good morning. 09:06
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` 5 Q You've -- you've been deposed a number of 09:06
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` 6 times before; is that right? 09:06
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` 7 A Yes, that's correct. 09:06
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` 8 Q So you're familiar with the deposition 09:06
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` 9 process, including the process for depositions 09:06
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` 10 before the Patent Trial and Appeal Board; is that 09:07
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` 11 right? 09:07
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` 12 A Yes. I have some familiarity. 09:07
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` 13 Q Okay. Have you had the opportunity to do a 09:07
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` 14 deposition by remote video using Zoom like we are 09:07
`
` 15 today? 09:07
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` 16 A No, I haven't. 09:07
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` 17 Q Okay. Are you familiar with the Zoom 09:07
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` 18 software? 09:07
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` 19 A A little bit, yes. 09:07
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` 20 Q Okay. So for the -- for introducing 09:07
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` 21 exhibits today, I will plan to publish PDFs of the 09:07
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` 22 exhibits that we're talking about using the Zoom 09:07
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` 23 chat function. And so on your window, you're Zoom 09:07
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` 24 window on your screen, you should see a button that 09:07
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` 25 says "chat." 09:07
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` 8
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 7
`
`
`
` 1 A Yes. 09:08
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` 2 Q And if you press that, you should see sort 09:08
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` 3 of a side window that right now has a PDF in it that 09:08
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` 4 you can download of what happens to be Exhibit 1003. 09:08
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` 5 Do you see that? 09:08
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` 6 (Exhibit 1003 was marked.) 09:08
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` 7 THE DEPONENT: Yes, and I am downloading it 09:08
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` 8 right now. 09:08
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` 9 BY MR. RUBIN: 09:08
`
` 10 Q Okay. 09:08
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` 11 A I have a folder called "Deposition Files," 09:08
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` 12 so I am going -- it's in folder, so I am going to 09:08
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` 13 download it there. 09:08
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` 14 Q And, then, I'm also planning on sharing my 09:08
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` 15 screen showing the -- the actual exhibits when I'm 09:08
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` 16 asking questions about it. So you should be able to 09:08
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` 17 see the exhibit we're talking about on the screen, 09:08
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` 18 but you can also feel free to download PDFs and 09:08
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` 19 review them if you need to. 09:08
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` 20 I think you just said that you also have a 09:09
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` 21 folder on your computer that has copies of the -- of 09:09
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` 22 various documents from this IPR; is that right? 09:09
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` 23 A Well, what I said is that I just created a 09:09
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` 24 new folder to put any files that I would download 09:09
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` 25 while we are in the deposition. And there's -- I do 09:09
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` 9
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 8
`
`
`
` 1 have a folder with some of the documents that I 09:09
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` 2 review for this deposition. 09:09
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` 3 Q Okay. Do you have paper copies of any of 09:09
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` 4 the documents related to the deposition with you? 09:09
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` 5 Or, I'm sorry, related to the IPR with you? 09:09
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` 6 A No. I don't think I have any other 09:09
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` 7 document. 09:09
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` 8 Q Okay. Do you have -- do you have any paper 09:09
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` 9 documents with you -- 09:10
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` 10 A I -- 09:10
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` 11 Q -- that you plan to consult during the 09:10
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` 12 deposition? 09:10
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` 13 A No. I have a few papers, but they are not 09:10
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` 14 related at all with this matter. 09:10
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` 15 Q Okay. So you indicated earlier you're 09:10
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` 16 familiar with the deposition process, so I won't 09:10
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` 17 belabor the details of that. But I will say if, at 09:10
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` 18 any point, one of my questions is unclear or you 09:10
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` 19 don't understand it, please ask me to clarify the 09:10
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` 20 question. Okay? 09:10
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` 21 A Thank you. 09:10
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` 22 Q And is it fair to assume that if you don't 09:10
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` 23 ask a clarification of the question, that you 09:10
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` 24 understand the question that's been asked? 09:10
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` 25 A Yes. And I will try to make sure I 09:11
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` 10
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 9
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`
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` 1 understand the questions. 09:11
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` 2 Q As we discussed before we went on the 09:11
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` 3 record, we are planning to take breaks approximately 09:11
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` 4 every hour. If, at any point, you do need to take a 09:11
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` 5 break, please let me know. But I will ask that you 09:11
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` 6 answer any pending question before we take the 09:11
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` 7 break. Okay? 09:11
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` 8 A Sure. 09:11
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` 9 Q And, then, you understand that while my 09:11
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` 10 questioning is ongoing, if we take breaks, you are 09:11
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` 11 not permitted to discuss the substance of your 09:11
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` 12 testimony with -- with counsel for Apple? 09:11
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` 13 A Yes, I understand that. 09:11
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` 14 Q Okay. And do you have any -- withdrawn. 09:11
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` 15 Is there anyone else in the room with you 09:11
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` 16 today during this deposition? 09:12
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` 17 A Except for my dogs, I'm alone in the house. 09:12
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` 18 Q Okay. And do you have any way of 09:12
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` 19 communicating with anyone else during the deposition 09:12
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` 20 concerning the -- concerning the deposition? 09:12
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` 21 A My local phone is disconnected so I don't 09:12
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` 22 get interrupted. And my cell phone is handy, and 09:12
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` 23 the only reason I have it is just in case we lose 09:12
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` 24 communication. 09:12
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` 25 Q Okay. All right. Is there any reason 09:12
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` 11
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 10
`
`
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` 1 today that you cannot give your full and complete 09:12
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` 2 testimony concerning this IPR? 09:12
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` 3 A No. 09:12
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` 4 Q So you're not suffering from any medical 09:14
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` 5 condition or taking any medication that would affect 09:13
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` 6 your memory or your ability to understand and answer 09:13
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` 7 questions? 09:13
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` 8 A Yes. I don't have a (unintelligible). 09:13
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` 9 CERTIFIED SHORTHAND REPORTER: I can't hear 09:13
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` 10 you. 09:13
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` 11 THE DEPONENT: No. I don't have any 09:13
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` 12 medical condition that I believe would prevent me 09:13
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` 13 from testifying today. 09:13
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` 14 BY MR. RUBIN: 09:13
`
` 15 Q Very good. 09:14
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` 16 So, as I said I would earlier, let me share 09:13
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` 17 a window from my screen which shows 09:13
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` 18 Exhibit APPL-1003, titled "Declaration of JosÈ 09:13
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` 19 Sasi·n, Ph.D., under 37 C.F.R. ß 1.68 in support of 09:14
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` 20 petition for inter partes review." 09:14
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` 21 Do you see that? 09:14
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` 22 A Yes. 09:14
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` 23 Q And do you recognize this as the 09:14
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` 24 declaration that you submitted in this IPR? 09:14
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` 25 A The front page of this published from the 09:14
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` 12
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 11
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`
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` 1 front page of my declaration. (Unintelligible.) 09:14
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` 2 CERTIFIED SHORTHAND REPORTER: I'm sorry. 09:14
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` 3 I can't understand you. 09:14
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` 4 THE DEPONENT: Okay. Just a second. Let 09:14
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` 5 me raise the volume here a little bit. 09:14
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` 6 Is this volume better? 09:14
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` 7 CERTIFIED SHORTHAND REPORTER: Yes, sir. 09:14
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` 8 THE DEPONENT: Okay. So I was saying that 09:14
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` 9 I recognize the front page of this document to be 09:14
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` 10 that of my declaration (inaudible) document are 09:14
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` 11 going to be (inaudible). 09:14
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` 12 BY MR. RUBIN: 09:14
`
` 13 Q So I'm afraid your -- the audio quality is 09:15
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` 14 a little uneven. You were kind of trailing off at 09:15
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` 15 the end of that answer, and I'm not sure whether 09:15
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` 16 that was -- I don't know if you moved relative to 09:15
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` 17 the microphone or something. 09:15
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` 18 A Okay. So I don't know. My volume here is 09:15
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` 19 (inaudible) and I don't -- I don't know if I can 09:15
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` 20 (inaudible) clearly or not. 09:15
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` 21 MS. SHI: Can we go off the record? 09:15
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` 22 CERTIFIED SHORTHAND REPORTER: Yes. 09:15
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` 23 MS. SHI: I can ask help Jose to connect 09:15
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` 24 maybe using the audio separately through the phone 09:15
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` 25 line. 09:15
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` 13
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 12
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`
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` 1 MR. RUBIN: Yeah. Let's go off the record. 09:15
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` 2 THE VIDEOGRAPHER: Okay. We are off record 09:15
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` 3 at 9:15. 09:15
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` 4 (A recess was taken.) 09:15
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` 5 THE VIDEOGRAPHER: We are back on the 09:31
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` 6 record at 9:30. 09:31
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` 7 BY MR. RUBIN: 09:31
`
` 8 Q Hello again. 09:32
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` 9 A Hello. 09:31
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` 10 Q So can you tell me -- is there anything 09:31
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` 11 that you're aware of in Exhibit 1003 that is 09:31
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` 12 inaccurate or that you'd like to change? 09:31
`
` 13 A At this moment, I don't recall or know of 09:31
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` 14 anything that I would like to change or that it's -- 09:31
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` 15 or where I may have a problem. I am not aware of 09:31
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` 16 anything at this moment. 09:32
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` 17 Q How many hours would you estimate you spent 09:32
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` 18 preparing this declaration? 09:32
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` 19 A Preparing the declaration? 09:32
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` 20 Q Correct. 09:32
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` 21 A Well, I -- I have no -- no idea of the 09:32
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` 22 number of hours I put into this right now. It was 09:32
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` 23 about one year ago or several months ago, and I 09:32
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` 24 don't recall the -- the number of hours I put into 09:32
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` 25 this, but probably more than 10, more than 20. I 09:32
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` 14
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 13
`
`
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` 1 don't recall. 09:32
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` 2 Q So it may have been more than 20 hours or 09:32
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` 3 it may have been less than 20 hours; is that right? 09:32
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` 4 A As I said, I really don't know, but I take 09:32
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` 5 it that it could have been 10, 20, 30 hours or more. 09:33
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` 6 I don't recall. 09:33
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` 7 Q Okay. There are printouts in -- well, 09:33
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` 8 withdrawn. 09:33
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` 9 So if we turn to the appendix of your 09:33
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` 10 declaration, there are a series of screen captures 09:33
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` 11 taken from the Zemax software; is that right? 09:33
`
` 12 A Yes. 09:33
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` 13 Q And did you prepare those screen captures 09:33
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` 14 yourself? 09:33
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` 15 A Yes. Yes. I -- I produced the -- the -- 09:33
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` 16 the screen captures, and that's what I did. I 09:34
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` 17 prepared the screen captures. 09:34
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` 18 Q How long would you estimate you spent using 09:34
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` 19 the Zemax software in preparing your declaration in 09:34
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` 20 this IPR? 09:34
`
` 21 A Would you please repeat the question? 09:34
`
` 22 Q So how much time would you estimate you 09:34
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` 23 spent prepare -- using the Zemax software to prepare 09:34
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` 24 the screen captures that are included in the 09:34
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` 25 appendix of your declaration? 09:34
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` 15
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 14
`
`
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` 1 A I don't have the exact recollection of the 09:34
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` 2 time; but I could guess that to prepare this 09:34
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` 3 printout, it took some time to input the 09:34
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` 4 prescription into the software and check the 09:35
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` 5 prescription, and that could have taken half an 09:35
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` 6 hour, one hour, and -- and then producing the 09:35
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` 7 printouts and pasting them, cropping from the Zemax 09:35
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` 8 screen. And pasting them into a -- a Microsoft 09:35
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` 9 document file would have taken a few minutes. But 09:35
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` 10 maybe half an hour, one hour per -- per printout. 09:35
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` 11 But I don't recall exactly the time I just spent on 09:35
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` 12 producing this, the screen captures of the lens 09:35
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` 13 information. 09:35
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` 14 Q So if we flip through the pages, we see 09:36
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` 15 that you have screen captures for four different 09:36
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` 16 example lens designs from Kawamura. Is your 09:36
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` 17 testimony that you spent approximately half an hour 09:36
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` 18 to an hour on each of those four? 09:36
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` 19 MS. SHI: Objection. Form. 09:36
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` 20 THE DEPONENT: No. What I said is that I 09:36
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` 21 don't recall the exact time I spent on this, and I 09:36
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` 22 was guessing more or less the time that one person 09:36
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` 23 will take in producing these things. 09:36
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` 24 BY MR. RUBIN: 09:36
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` 25 Q Okay. Now, in this declaration, you offer 09:37
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` 16
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 15
`
`
`
` 1 opinions that relate to the validity of Claims 5 and 09:36
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` 2 6 of the '408 Patent; is that right? 09:36
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` 3 A Yes. 09:37
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` 4 Q And if we turn to page 18 of the 09:37
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` 5 declaration, you identify Ground 1 as Claims 5 to 6 09:37
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` 6 are unpatentable under 35 U.S.C. Section 103 over 09:37
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` 7 Golan and Kawamura. You see that? 09:37
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` 8 A Yes. 09:37
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` 9 Q So the opinions that you offer in this 09:37
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` 10 declaration relate solely to obviousness over the 09:37
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` 11 combination of Golan with Kawamura. Would you 09:37
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` 12 agree? 09:37
`
` 13 A Yes. And let me restate what you said, 09:37
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` 14 because I may have lost a word. 09:38
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` 15 So my understanding is that the question 09:38
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` 16 was whether I relied solely -- solely on Kawamura 09:38
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` 17 and Golan for this combination, and -- and as prior 09:38
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` 18 art, yes, I do rely on them. 09:38
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` 19 Q So you haven't offered any opinion that 09:38
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` 20 Golan by itself satisfies the elements of Claim 5 or 09:38
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` 21 the elements of Claim 6; correct? 09:38
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` 22 A Yes. I'm not offering an opinion only that 09:38
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` 23 is on Golan. 09:38
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` 24 Q And, likewise, you're not offering an 09:38
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` 25 opinion that Kawamura by itself satisfies each of 09:38
`
` 17
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 16
`
`
`
` 1 the elements of Claim 5 or Claim 6; correct? 09:39
`
` 2 A That's correct. 09:39
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` 3 MS. SHI: Objection. Form. 09:39
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` 4 BY MR. RUBIN: 09:39
`
` 5 Q All right. Now, turning to the actual 09:41
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` 6 claim elements as you've identified them in this 09:39
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` 7 declaration, I'm looking now at page 28 of your 09:39
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` 8 declaration, where you discussed the preamble of 09:39
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` 9 Claim 5. You rely solely on the Golan prior 09:39
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` 10 reference to satisfy this preamble; correct? 09:40
`
` 11 A As -- as far as the preamble is refer, yes. 09:40
`
` 12 Q And you don't have any opinion that 09:40
`
` 13 Kawamura discloses a zoom digital camera; correct? 09:40
`
` 14 A May I ask you what do you mean by a -- a -- 09:41
`
` 15 a -- well, actually, would you please repeat the 09:41
`
` 16 question? 09:41
`
` 17 Q You don't offer any opinion that Kawamura 09:41
`
` 18 discloses a zoom digital camera; correct? 09:41
`
` 19 A Yes. I don't offer an opinion on that. 09:41
`
` 20 Q And if we turn to -- if we turn to page 30 09:41
`
` 21 of your declaration where you begin your discussion 09:41
`
` 22 of Element A of Claim 5, you rely solely on Golan to 09:41
`
` 23 satisfy Element A of Claim 5; is that right? 09:42
`
` 24 A Yes. 09:42
`
` 25 Q Now, turning to page 34 of your 09:43
`
` 18
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 17
`
`
`
` 1 declaration, you have a section where you discuss 09:43
`
` 2 the first portion Element B of Claim 5, quote: 09:43
`
` 3 "A second imaging section that includes 09:43
`
` 4 a fixed focal length second lens with a 09:43
`
` 5 second FOV (FOV2) that is narrower than 09:43
`
` 6 FOV1, and a second image sensor." 09:43
`
` 7 Do you see that? 09:43
`
` 8 A Yes. 09:43
`
` 9 Q And for this portion of Element B of 09:43
`
` 10 Claim 5, again, you rely solely on Golan to satisfy 09:43
`
` 11 this limitation; correct? 09:43
`
` 12 A Yes. 09:43
`
` 13 Q And you don't offer any opinion that 09:44
`
` 14 Kawamura discloses a second imaging section with a 09:44
`
` 15 fixed focal length second lens with a second FOV 09:44
`
` 16 that is narrower than FOV1; correct? 09:44
`
` 17 A Yes. 09:44
`
` 18 Q Now, on page 37, you begin your discussion 09:44
`
` 19 of the next portion of Element B of Claim 5. And 09:44
`
` 20 for this portion of Element B, you rely solely on 09:44
`
` 21 Kawamura. Would you agree? 09:44
`
` 22 A Well, what I state on Paragraph 83 is that 09:45
`
` 23 Golan in view of Kawamura renders obvious that the 09:45
`
` 24 second lens includes five lens elements. 09:45
`
` 25 Q But Golan doesn't talk about five lens 09:45
`
` 19
`
`APPLE V COREPHOTONICS
`IPR2020-00905
`Exhibit 2026
`Page 18
`
`
`
` 1 elements; correct? 09:45
`
` 2 A Yes. Golan doesn't talk about five lens 09:45
`
` 3 elements. 09:45
`
` 4 Q And Golan doesn't talk about certain lens 09:45
`
` 5 elements having positive power or certain lens 09:45
`
` 6 elements having negative power; correct? 09:45
`
` 7 A That's correct. 09:46
`
` 8 Q Golan doe
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