Page 1
`
` UNITED STATES PATENT AND TRADEMARK
`
` ______________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
`
`SAMSUNG DISPLAY CO., LTD., SAMSUNG ELECTRONICS CO.,
` LTD., AND SAMSUNG ELECTRONICS AMERICA, INC.
`
` Petitioner
`
` v.
`
` SOLAS OLED LTD.
`
` Patent Owner.
` ______________________________
`
` IPR2021-00591
`
` Patent 7,868,880
`
` ZOOM DEPOSITION OF MILTIADIS HATALIS, Ph.D.
`
`(Reported Remotely via Video & Web Videoconference)
`
` Bethlehem, Pennsylvania (Deponent's location)
`
` Wednesday, December 29, 2021
`
`Reported by:
`
`REBECCA L. ROMANO, RPR, CSR, CCR
`California CSR No. 12546
`Nevada CCR No. 827
`Oregon CSR No. 20-0466
`Washington CCR No. 3491
`
`Job No.: 3883
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 1
`
`
`
` UNITED STATES PATENT AND TRADEMARK
`
` ______________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
`
`SAMSUNG DISPLAY CO., LTD., SAMSUNG ELECTRONICS CO.,
` LTD., AND SAMSUNG ELECTRONICS AMERICA, INC.
`
` Petitioner
`
` v.
`
` SOLAS OLED LTD.
`
` Patent Owner.
` ______________________________
`
` IPR2021-00591
`
` Patent 7,868,880
`
` ZOOM DEPOSITION OF MILTIADIS HATALIS, Ph.D.
`
`(Reported Remotely via Video & Web Videoconference)
`
` Bethlehem, Pennsylvania (Deponent's location)
`
` Wednesday, December 29, 2021
`
`Reported by:
`
`REBECCA L. ROMANO, RPR, CSR, CCR
`California CSR No. 12546
`Nevada CCR No. 827
`Oregon CSR No. 20-0466
`Washington CCR No. 3491
`
`Job No.: 3883
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 1
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`Page 2
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` UNITED STATES PATENT AND TRADEMARK
`
` ______________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
`
`SAMSUNG DISPLAY CO., LTD., SAMSUNG ELECTRONICS CO.,
` LTD., AND SAMSUNG ELECTRONICS AMERICA, INC.
`
` Petitioner
`
` v.
`
` SOLAS OLED LTD.
`
` Patent Owner.
` ______________________________
`
` IPR2021-00591
`
` Patent 7,868,880
`
` DEPOSITION OF MILTIADIS HATALIS, Ph.D.,
`
`taken on behalf of the Patent Owner, with the
`
`deponent located in Bethlehem, Pennsylvania,
`
`commencing at 10:06 a.m., Wednesday,
`
`December 29, 2021, remotely reported via Video &
`
`Web videoconference before REBECCA L. ROMANO, a
`
`Certified Shorthand Reporter, Certified Court
`
`Reporter, Registered Professional Reporter
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 2
`
`
`
`Page 3
`
` APPEARANCES OF COUNSEL
`
`(All parties appearing via Web videoconference)
`
`For the Petitioner - SAMSUNG DISPLAY CO., LTD.,
`SAMSUNG ELECTRONICS CO., LTD., AND SAMSUNG
`ELECTRONICS AMERICA, INC.:
`
` O'MELVENY & MYERS
`
` BY: BRIAN COOK
`
` Attorney at Law
`
` 400 South Hope Street
`
` 18th Floor
`
` Los Angeles, California 90071
`
` (213) 430-6000
`
` bcook@omm.com
`
`For the Patent Owner - Solas OLED LTD.:
`
` RUSS AUGUST & KABAT
`
` BY: NEIL A. RUBIN
`
` Attorney at Law
`
` 12424 Wilshire Boulevard
`
` 12th Floor
`
` Los Angeles, California 90025
`
` (310) 826-7474
`
` nrubin@raklaw.com
`
`ALSO PRESENT:
`
` Raghib Page, Videographer
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 3
`
`
`
`Page 4
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` I N D E X
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`DEPONENT EXAMINATION
`
`MILTIADIS HATALIS, PH.D. PAGE
`
` BY MR. RUBIN 8
`
` E X H I B I T S (premarked)
`
`NUMBER PAGE
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` DESCRIPTION
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`Exhibit 1003 Declaration of Miltiadis 11
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` Hatalis, Ph.D., in Support
`
` of Petition for Inter Partes
`
` Review of U.S. Patent
`
` No. 7,868,880;
`
`Exhibit 1004 Curriculum Vitae; 11
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`Exhibit 1006 United States Patent 11
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` Application Publication
`
` US 2005/0083270 A1;
`
`Exhibit 1008 International Publication 11
`
` Number WO 2004/040543 A2;
`
`/////
`
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`212-400-8845 - Depo@TransPerfect.com
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 4
`
`
`
`Page 5
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` E X H I B I T S (premarked)
`
`NUMBER PAGE
`
` DESCRIPTION
`
`Exhibit 1009 International Publication 11
`
` Number WO 2004/086347 A2.
`
`/////
`
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`212-400-8845 - Depo@TransPerfect.com
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 5
`
`
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` Bethlehem, Pennsylvania;
`
` Wednesday, December 29, 2021
`
` 10:06 a.m.
`
` ---o0o---
`
`Page 6
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` THE VIDEOGRAPHER: Okay. We're now on
`
`the record. Today's date is December 29th, 2021,
`
`and the time is 10:05 -- 10:06 a.m. -- excuse me --
`
`Eastern Standard Time. This is the video
`
`deposition of Dr. Miltiadis Hatalis in the matter
`
`of Solas OLED Ltd. versus Samsung Display Co. Ltd.
`
` My name is Raghib Page. I'm the
`
`videographer representing TransPerfect.
`
` Would counsel on the conference call
`
`please identify yourself and state whom you're
`
`representing, beginning with the questioning
`
`attorney.
`
` MR. RUBIN: This is Neil Rubin of Russ
`
`August & Kabat representing the Patent Owner, Solas
`
`OLED, Limited.
`
` MR. COOK: And this is Brian Cook with
`
`O'Melveny & Myers representing the petitioner,
`
`Samsung.
`
` THE VIDEOGRAPHER: Okay. Thank you,
`
`Counsel.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 6
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` Our court reporter today is
`
`Rebecca Romano, representing TransPerfect as well.
`
`The court reporter will now swear in the witness.
`
` THE COURT REPORTER: At this time, I will
`
`ask counsel to agree on the record that there is no
`
`objection to this deposition officer administering
`
`a binding oath to the deponent via remote
`
`videoconference, starting with the noticing
`
`attorney, please.
`
` MR. RUBIN: No objection for the Patent
`
`Owner.
`
` MR. COOK: No objection.
`
` THE COURT REPORTER: Doctor, if you could
`
`raise your right hand for me, please.
`
` THE DEPONENT: (Complies.)
`
` THE COURT REPORTER: You do solemnly
`
`state, under penalty of perjury, that the testimony
`
`you are about to give in this deposition shall be
`
`the truth, the whole truth and nothing but the
`
`truth?
`
` THE DEPONENT: I do.
`
`/////
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 7
`
`
`
` MILTIADIS HATALIS, Ph.D.,
`
`having been administered an oath, was examined and
`
`Page 8
`
`testified as follows:
`
` EXAMINATION
`
`BY MR. RUBIN:
`
` Q. Good morning, sir.
`
` A. Good morning.
`
` Q. And can you please pronounce your last
`
`name just so I make sure I'm saying it correctly?
`
` A. Hatalis.
`
` Q. Hatalis. All right. Thank you very
`
`much.
`
` And, Dr. Hatalis, have you been deposed
`
`before?
`
` A. Yes.
`
` Q. How many times?
`
` A. About 30.
`
` Q. And so I think -- it sounds like it would
`
`be fair to say that you're familiar with the
`
`deposition process, then?
`
` A. I am.
`
` Q. So I won't belabor the preliminaries. I
`
`will say if you have -- if at any point you don't
`
`understand a question that I have asked, please let
`
`me know and I will attempt to clarify. Okay?
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 8
`
`
`
`Page 9
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` A. Okay.
`
` Q. And during today's deposition, I'll plan
`
`on taking breaks every hour to hour and a half. If
`
`at any point you need a break, please let me know.
`
` A. Okay.
`
` Q. Is there any reason that you're aware of
`
`that you cannot give your full and complete
`
`testimony here today?
`
` A. There's no reason.
`
` Q. And in particular, are you suffering from
`
`any medical condition or taking any medication that
`
`would affect your ability to understand or answer
`
`questions?
`
` A. No, I am not.
`
` Q. And those approximately 30 depositions
`
`that you referred to earlier, were those all
`
`depositions that you provided as an expert witness?
`
` I'm sorry --
`
` A. Yes, that is correct.
`
` Q. Okay. And how many of those cases were
`
`patent cases?
`
` A. All of them.
`
` Q. And how many cases were you engaged as an
`
`expert by Samsung?
`
` A. Several.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 9
`
`
`
` Q. What would be your best estimate of how
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`Page 10
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`many?
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` A. I don't have them all in my CV, but I
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`would say at least a dozen. Maybe a dozen. About
`
`a third.
`
` Q. So your estimate is that about a third of
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`the cases where you've been deposed as an expert,
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`you were serving as an expert for Samsung; is that
`
`right?
`
` A. That is an estimate.
`
` Q. And how many of the cases where you've
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`been deposed as an expert was the law firm that
`
`engaged you O'Melveny & Myers?
`
` A. There -- there were a few. I don't
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`remember the exact number. Again, I don't have my
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`CV in front of me, but there were a few.
`
` Q. What would be your -- your best estimate
`
`of the number?
`
` A. Probably six.
`
` Q. Well, you referred to your CV. Do you
`
`have any -- well, let me step back.
`
` Do you have any documents with you today
`
`during the deposition?
`
` A. I have my declaration, and actually I
`
`have some of the exhibits. You want me to -- to
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 10
`
`
`
`list them as exhibit numbers?
`
`Page 11
`
` Q. Yeah. How about you do that.
`
` A. Okay. I have my declaration, which is
`
`Exhibit 1003. I have the '880 patent, which is
`
`Exhibit 1001. I have a claims listing,
`
`Exhibit 1002. I have the -- the Miyazawa patent,
`
`Exhibit 1006. I have the Morosawa patent,
`
`Exhibit 1008. I have the Shirasaki patent,
`
`Exhibit 1009. I have the Schechter patent,
`
`Exhibit 1010. I have the Koyama patent,
`
`Exhibit 1011. I have the Exhibit 1007, and I have
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`file history which is Exhibit 1005.
`
` Q. And those paper copies of exhibits that
`
`you just listed that you have with you today, are
`
`there any notes or is there any highlighting on any
`
`of those paper copies?
`
` A. No.
`
` Q. So is it your understanding that those --
`
`the copies that you have are identical to the
`
`exhibits that were filed in the case?
`
` A. I -- yes.
`
` Q. So I've just uploaded, using the Zoom
`
`chat function, a copy of Exhibit 1004, which is
`
`your CV filed in this case.
`
` Are you able to download that and open
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`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 11
`
`
`
`Page 12
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`that on your computer?
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` A. Where do you download it, you said?
`
` Q. So in the -- in your Zoom window at the
`
`bottom of the screen, you should see a series of
`
`icons. One of them is labeled "chat."
`
` A. Correct.
`
` Q. So if you click on that, it should open a
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`sort of a side window where -- you know, I'm sorry.
`
`I actually did not share that with everyone, so let
`
`me try that again.
`
` Okay. So now you should see in that side
`
`window a chat from me that attached a copy of
`
`Exhibit 1004.
`
` A. Yes, I can see it.
`
` Q. And I will also share this document on
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`the screen. Can you see it?
`
` A. Yes, I can see it.
`
` Q. So turning to page 3 of your CV,
`
`Exhibit 1001. It lists -- it says "total court
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`appearances, one; total expert reports, 34;
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`IPR-related reports, 19; total reports deposed,
`
`22."
`
` Do you see that?
`
` A. Yes.
`
` Q. And are the cases listed under that on
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 12
`
`
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`Page 13
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`pages 3 through 5 of your CV, are those all the
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`cases that you've served as an expert witness in
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`your career?
`
` A. If you move up to page 3, you can see at
`
`the top there is -- there's a note that says
`
`"cases," and then the next to it says "cases
`
`completed."
`
` So, yes, these are the completed cases.
`
`Yes, sir.
`
` Q. And when you say "total reports deposed,
`
`22," I think earlier today you estimated there were
`
`over 30 cases -- or 30 depositions that you'd had.
`
`Is 22 the actual number, or are there additional
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`depositions beyond the ones that are listed here?
`
` A. As far as the cases completed.
`
` Q. I see.
`
` A. And then there are patent cases such as
`
`this one, which are still ongoing, and those ones
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`are not listed -- are not included in those lists.
`
`So cases that have been recently completed or are
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`ongoing are not listed in -- in this CV. This CV
`
`was filed some time ago, in the beginning of last
`
`year. So there have been additional cases, and
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`some cases have been completed since then. None of
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`those are included in -- in this report.
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 13
`
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` When you're asking about total
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`Page 14
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`depositions that I -- that I participate, I
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`included the ones that were among those
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`cases that -- either current cases or recently
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`completed but had not made it to the list yet.
`
` Q. Okay. So you have a copy of your
`
`declaration, so I won't upload an electronic
`
`version unless for some reason you'd like me to do
`
`that. But I will show it on the screen just so
`
`that we can make sure we're looking at the same
`
`thing.
`
` Is that okay?
`
` A. That's fine.
`
` Q. All right. So I take it you recognize
`
`the document on the screen as the declaration that
`
`you submitted in this case, Exhibit 1003?
`
` A. I do recognize it.
`
` Q. So I'd like to start out with grounds
`
`1/1a, at least what you label as such, and your
`
`discussion of these grounds starts on -- well,
`
`let's go back.
`
` So as you see on this page, there are two
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`sets of page numbers in the document. There's page
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`number at the very bottom of the page -- for
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`example, in this case, page 27 of 164 -- and then
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 14
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`there's a page number a bit above that in this
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`case, page 22.
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` Do you see that?
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` A. Yes, I do.
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` Q. And so I take it that the page 22 here
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`would be sort of the internal page numbering of the
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`document that you saw as it was being prepared, and
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`then the other page numbering at the bottom was
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`something that was added when the document was
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`filed.
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` So I will plan to refer to the internal
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`page number in the case of this page on the screen,
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`page 22; is that okay?
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` A. Yeah.
`
` Q. So the section heading 7A on this page
`
`refers to grounds 1/1a.
`
` Do you see that?
`
` A. Yeah.
`
` Q. So do you have an understanding of what
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`ground 1 is and what ground 1a is?
`
` A. Yes.
`
` Q. What's the difference between ground 1
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`and ground 1a --
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` A. 1 is the ground that based on
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`anticipation, and 1 -- 1a is the ground based on --
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 15
`
`
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` (Court Reporter asks clarification.)
`
` THE DEPONENT: The ground 1 is for
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`anticipation and ground 1a is for --
`
` MR. RUBIN: I think the word you may be
`
`struggling with is "obviousness."
`
` THE DEPONENT: Correct.
`
` Q. (By Mr. Rubin) On page 28, paragraph 54,
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`the second sentence reads "Any limitation not
`
`explicitly or implicitly disclosed by Miyazawa
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`would have been obvious because a person of skill
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`of the art would have been motivated to modify
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`Miyazawa using well-known OLED design techniques to
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`achieve more accurate luminance programming and
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`emission."
`
` Do you see that?
`
` A. Yeah.
`
` Q. Now, do you recall if there are any
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`limitations for which you provide an obviousness
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`analysis for Miyazawa beyond this statement in
`
`paragraph 54?
`
` A. My -- my analysis concerned that Miyazawa
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`anticipates the -- '880 patent, that -- to the
`
`extent that someone may -- may disagree with my
`
`analysis, that all elements are disclosed in
`
`Miyazawa. Then I would value the statement and say
`
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 16
`
`
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`that if someone disagrees with my anticipation
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`analysis, then that particular element that someone
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`may argue being obvious to the person skilled in
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`the art. Based on my analysis, Miyazawa
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`anticipates what the '880 patent.
`
` Q. So when I do a search for the word
`
`"obvious" in the section of your declaration
`
`concerning grounds 1 and 1a, I see that word appear
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`twice. So once is in this sentence from paragraph
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`54 that we just looked at, and then the second time
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`that I see the word "obvious" is in paragraph 62 of
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`your declaration concerning limitation 1.5.
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` Are you aware of any discussion or
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`analysis pertaining to obviousness of claims based
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`on Miyazawa in your declaration other than the
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`statements in paragraph 54 and paragraph 62?
`
` A. I -- I do not recall. I -- you want me
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`to review the -- the ground 1 and 1a and confirm
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`whether those two are the only ones or are there
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`other ones, but...
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` Q. Well, so I'll represent to you if you
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`search the word "obvious," those are the only two
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`paragraphs where it appears. And if I understand
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`you correctly, you're saying you don't recall there
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`being any other place in the Miyazawa section in
`
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 17
`
`
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`your declaration that discusses obviousness; is
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`that right?
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` A. Well, I -- I do not recall whether this
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`statement is true or actually whether other things
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`have been stated that would be pursued as being an
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`obviousness analysis. But I would like to confirm
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`that my primary analysis have found that Miyazawa
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`anticipates the '880 patent, and whatever -- such
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`as this analysis or this statement shown here that
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`it had been obvious such that the elements do not
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`take -- do not remove the validity of my analysis
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`in my opinion. It just to the extent that someone
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`disagrees with my analysis, then I say that it
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`should be obvious.
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` I do not agree or disagree with your
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`words but -- but just could not memorize the full
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`analysis here. So I'm -- I'm not -- I don't know
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`how you construe some of my other statement.
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` I'm -- I'm not a lawyer. I am a
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`technical expert, so based on my opinion, an
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`analysis I -- I found the Miyazawa anticipates the
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`'880 patent.
`
` Q. So turning to this sentence in paragraph
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`62 that contains the word "obvious," you say,
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`quote, "To the extent the state setting unit is not
`
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 18
`
`
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`expressly disclosed, it would have been obvious
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`that because SEL2 and SEL3 have waveforms different
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`from SEL1, distinct logic in the scanning line
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`driving circuit and/or control circuit would
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`generate the waveforms that drive these bias
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`lines."
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` Do you see that?
`
` A. Correct.
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` Q. So aside from that sentence, do you
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`recall offering any opinions in your declaration
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`about how a person of ordinary skill in the art
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`might have modified Miyazawa or added anything to
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`Miyazawa in order to produce a device that
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`satisfies the claims of the '880 patent?
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` A. In my analysis, I found that there's
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`no -- that Miyazawa discloses everything required
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`to -- to meet the anticipation ground. This is one
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`case where the teaching of Miyazawa could be
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`construed by the others as not being --
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`particularly lawyers or a person who's not skilled
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`in the art -- is not -- not being directly
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`disclosed.
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` I believe to a person skilled in the art,
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`the teaching of Miyazawa is -- is plentiful, and
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`based on that teaching, a person skilled in the art
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`TransPerfect Legal Solutions
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 19
`
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`would understand that the state setting unit would
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`Page 20
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`be disclosed.
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` But if my report is -- is viewed by a
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`person not skilled in the art and to the extent
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`that someone express such an opinion, I would -- I
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`view that that would be obvious to have implemented
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`as a separate state setting unit.
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` Does that answer your question?
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` Q. Partially. My question was whether you
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`had provided any opinions about modifications or
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`additions to the teachings in Miyazawa that a
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`person of ordinary skill in the art might have made
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`and that would have satisfied limitations of the
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`'880 patent claims other than the state setting
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`unit limitation you're discussing in paragraph 62.
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` A. My -- my recollection of the report is --
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`as a whole, particular in this ground 1, is that my
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`analysis has indicated that no modifications and no
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`changes are needed, that the teaching of Miyazawa
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`would have been clear to a person skilled in the
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`art, and that's -- and a person skilled in the art
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`would have seen that all -- all claims in the
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`'880 patent are -- are disclosed and has -- it is
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`my opinion as a technical expert, looking at this
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`document from the point of view of a person skilled
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 20
`
`
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`in the art, that everything in Miyazawa that are
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`disclosed by the '880 patent are taught by
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`Miyazawa.
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` Q. And so because that's your opinion, you
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`didn't analyze any modifications that might have
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`been made to Miyazawa as part of your obviousness
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`analysis; is that right?
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` MR. COOK: Object to the form.
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` THE DEPONENT: I said I do -- I do not
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`recall the entire document. I gave you the high
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`level. If there is a section in my analysis that
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`you think is -- is leaning in that direction,
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`please bring it to me, to my attention, as you have
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`done for -- for this particular limitation, which
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`is the state setting unit. Only then I can
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`elaborate more.
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` It's my recollection that Miyazawa
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`discloses all the elements, all the limitations
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`within the claim, and hence anticipates the
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`'880 patent.
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` Now, there are -- my statement is with
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`respect to the claims that I cite. I believe there
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`is at least one claim has not been anticipated, so
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`my statement is valid for the -- the claims that I
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`analyze and present in the report. It's not for
`
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 21
`
`
`
`Page 22
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`all of the claims for '880 patent, but for the ones
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`that I'm expressing an opinion in my report.
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` So when I say "anticipate," anticipates
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`the claims that are listed in the ground 1.
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` Q. (By Mr. Rubin) Understood.
`
` A. Because I thought we were discussing the
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`ground 1. Not -- not all claims are listed in
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`ground 1.
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` Q. Back to your discussion of Miyazawa
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`starting at page 22. On page 24 you say that "SEL2
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`and SEL3 (purple) are bias lines."
`
` Do you see that?
`
` A. Yes, I see that.
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` Q. And "bias line" is a term that's used in
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`several of the claims of the '880 patent; is that
`
`right?
`
` A. Correct.
`
` Q. So turn, for example, to paragraph 58.
`
`You're addressing claim element 1.2, which requires
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`"a plurality of bias lines."
`
` Do you see that?
`
` A. Yeah.
`
` Q. And you say "the disclosed SEL2 and SEL3
`
`(purple) operate as bias lines."
`
` Do you see that?
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`TransPerfect Legal Solutions
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 22
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`
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` A. I see that.
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` Q. So in your mapping of the term "plurality
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`of bias lines" in the claim onto Miyazawa's fourth
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`embodiment, are you saying that both the -- that
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`that term, "plurality of bias lines," maps onto
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`the -- well, withdrawn.
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` In your mapping of the '880 patent claims
`
`onto the Miyazawa prior art, is the, quote,
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`"plurality of bias lines" made up all of the SEL2
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`lines and all of the SEL3 lines?
`
` A. For -- for a given row, the '880 patent
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`is -- is disclosing a single bias line. The -- and
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`when you say "a plurality of bias lines" in -- in
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`'880, that refers to multiple roles; hence, there
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`would be multiple bias lines where you have one per
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`row.
`
` In the embodiment 4 of Miyazawa, there
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`are two bias lines per row. So if you're talking
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`about the plurality of roles, then all those bias
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`lines will be included in -- in the limitation of
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`this claim.
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` Now, there are other embodiments in
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`Miyazawa which are -- which are not included, and
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`not all of them disclose two bias lines.
`
` Q. So why is it in your opinion that the
`
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 23
`
`
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`plurality of bias lines includes both the SEL2
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`lines and SEL3 lines?
`
` A. Because they both serve -- serve a
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`purpose in the -- in the embodiment 4 of Miyazawa.
`
` Q. And what's that purpose?
`
` A. It's discussed in detail as we move to
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`the other limitations of the -- that analyze -- for
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`this claim as well as for the other claims. And
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`you want me to go in each of one of those
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`limitations and -- and point out all of the SEL2
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`line and all of the SEL3 line? You want me to go
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`to a specific one? There's many, many limitations.
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`You want me to go through all of them?
`
` Q. Right.
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` Well, we'll go through some of those
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`other limitations, I think, later today.
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` But is it fair to say that you explain at
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`least one reason that the SEL2 and SEL3 lines
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`operate as bias lines in the same sentence when you
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`say, quote, "because they control T2 and T4 used to
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`eliminate the charge stored on capacitors C1 and
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`C2"?
`
` Would that be one reason that both SEL2
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`and SEL3 operate as bias lines?
`
` A. Based on the -- on the circuitry in -- in
`
`TransPerfect Legal Solutions
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`
`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 24
`
`
`
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`Miyazawa embodiment 4, when the SEL2 and the SEL3
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`bias lines are turning on, then the different --
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`the different -- different circuit connections are
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`formed, and those circuit connections are resolved
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`in meeting some of the claims, some of the
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`limitations of the other claims.
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` Now, as far as this particular
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`limitation, only one of those lines will be
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`sufficient to -- to meet the claim, because the
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`claims says the plurality of bias lines, so even if
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`I have pointed to the SEL2 line alone, because of
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`the plurality of rows, there will be a plurality of
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`SEL2 lines. So that -- that would be sufficient, I
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`believe, to meet this particular lay claim
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`limitation, based on my understanding of the law.
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` Q. So I'd like to talk in some more detail
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`about the circuit shown in Miyazawa Figure 9 and
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`the timing diagram shown in Miyazawa Figure 10.
`
`You should see on your screen side by side pages 32
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`and 33 of your declaration.
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` Are you able to see that?
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` A. I can see that, yes.
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` Q. And so is it your understanding that
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`Figure 10 of Miyazawa shows the timing diagram of
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`the signals that are applied to the circuit shown
`
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`SAMSUNG V. SOLAS
`IPR2021-00591
`Exhibit 2003
`Page 25
`
`
`
`Page 26
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`in Figure 9 of Miyazawa?
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` A. Correct, within one frame time. From the
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`beginning of the frame, which starts at t0, to the
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`end of the frame, which is -- completes the time,
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`t3.
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` Q. I'd like to talk about the process of --
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`I'd like -- I'd like to talk about how the -- the
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`charges and voltages on the capacitors C1 and C2
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`change over time in this timing diagram.
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` So immediately -- well --
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` So in claim limitation 1.3, there's a
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`requirement of setting pixels "to a selection
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`state."
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` Do you see that?
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` A. Yes, I see that.
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` Q. And so turning to the timing diagram on
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`page 33 -- Figure 10 of Miyazawa, rather -- when,
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`in
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