UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` SAMSUNG DISPLAY CO., LTD.,
`
` SAMSUNG ELECTRONICS CO., LTD., and
`
` SAMSUNG ELECTRONICS AMERICA, INC.,
`
` Petitioners,
`
` v.
`
` SOLAS OLED LTD.,
`
` Patent Owner.
`
` ____________
`
` Case No. IPR2021-00591
`
` U.S. Patent No. 7,868,880
`
` ____________
`
` VIRTUAL VIDEOCONFERENCE VIDEO-RECORDED
`
` DEPOSITION OF THOMAS CREDELLE
`
` Monday, April 18, 2022
`
` Remotely Testifying from Powell Butte, Oregon
`
` Reported By: Hanna Kim, CLR, CSR No. 13083
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`Page 1
`
`Petitioner Samsung Ex. 1014
`Page 001
`
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` SAMSUNG DISPLAY CO., LTD.,
`
` SAMSUNG ELECTRONICS CO., LTD., and
`
` SAMSUNG ELECTRONICS AMERICA, INC.,
`
` Petitioners,
`
` v.
`
` SOLAS OLED LTD.,
`
` Patent Owner.
`
` ____________
`
` Case No. IPR2021-00591
`
` U.S. Patent No. 7,868,880
`
` ____________
`
` VIRTUAL VIDEOCONFERENCE VIDEO-RECORDED
`
` DEPOSITION OF THOMAS CREDELLE
`
` Monday, April 18, 2022
`
` Remotely Testifying from Powell Butte, Oregon
`
` Reported By: Hanna Kim, CLR, CSR No. 13083
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`Veritext Legal Solutions
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`Page 1
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`Petitioner Samsung Ex. 1014
`Page 001
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` SAMSUNG DISPLAY CO., LTD.,
`
` SAMSUNG ELECTRONICS CO., LTD., and
`
` SAMSUNG ELECTRONICS AMERICA, INC.,
`
` Petitioners,
`
` v.
`
` SOLAS OLED LTD.,
`
` Patent Owner.
`
` ____________
`
` Case No. IPR2021-00591
`
` U.S. Patent No. 7,868,880
`
` ____________
`
` Virtual videoconference video-recorded
`
` deposition of THOMAS CREDELLE, taken on
`
` behalf of the Petitioners, on April 18,
`
` 2022, before Hanna Kim, CLR, Certified
`
` Shorthand Reporter, No. 13083.
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`Page 2
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`Petitioner Samsung Ex. 1014
`Page 002
`
`
`
` REMOTE VIDEOCONFERENCE APPEARANCES OF COUNSEL:
`
` FOR SAMSUNG DISPLAY CO., LTD., SAMSUNG ELECTRONICS
`
` CO., LTD., AND SAMSUNG ELECTRONICS AMERICA, INC.:
`
` O'MELVENY & MYERS LLP
`
` BY: BRIAN COOK, ESQ.
`
` 1999 Avenue of the Stars, Suite 700
`
` Los Angeles, California 90067
`
` 213.430.6496
`
` bcook@omm.com
`
` FOR PATENT OWNER, SOLAS OLED LTD.:
`
` RUSS AUGUST & KABAT
`
` BY: NEIL A. RUBIN, ESQ.
`
` 12424 Wilshire Blvd.
`
` Los Angeles, California 90025
`
` 310.826.7474
`
` nrubin@raklaw.com
`
` ALSO PRESENT:
`
` KIMBERLEE DECKER, Video Operator
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`Page 3
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`Petitioner Samsung Ex. 1014
`Page 003
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`
`
` INDEX OF EXAMINATION
`
` WITNESS: THOMAS CREDELLE
`
` EXAMINATION PAGE
`
` BY MR. COOK: 7
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`Petitioner Samsung Ex. 1014
`Page 004
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`
`
` INDEX OF EXHIBITS
`
`CREDELLE DEPOSITION EXHIBITS PAGE
`
`Exhibit 1013 Copy of public version of trial 14
`
` testimony from ITC
`
` Investigation No. 337-TA-1243,
`
` November 16, 2021; 48 pages
`
`PREVIOUSLY MARKED EXHIBITS REFERENCED PAGE
`
`Deposition Exhibit 2001 10
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`Deposition Exhibit 1001 18
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`Deposition Exhibit 1008 23
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`Deposition Exhibit 1006 28
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`Deposition Exhibit 1009 129
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`Page 5
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`Petitioner Samsung Ex. 1014
`Page 005
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` Remotely Testifying from Powell Butte, Oregon
`
` Monday, April 18, 2022; 11:06 a.m., PDT
`
` --o0o--
`
` THE VIDEOGRAPHER: Good morning. We are
`
` on record at 11:06 a.m. -- wait, that's not right. 11:06:16
`
` Yep, 11- -- 11:06 a.m., sorry, on April the 18th of
`
` 2022.
`
` All participants are attending remotely.
`
` Audio and video recording will continue to
`
` take place, unless all parties agree to go off the 11:06:35
`
` record.
`
` This is Media Unit 1 of the recorded
`
` deposition of Thomas Credelle, taken by counsel for
`
` the Petitioner, in the matter of Samsung Display
`
` Company, Limited, versus Solas OLED LTD., filed 11:06:51
`
` with the U.S. Patent and Trademark Office, Case
`
` Number IPR2021-00591.
`
` My name is Kimberlee Decker, from Veritext
`
` Legal Solutions, and I am the videographer.
`
` The court reporter is Hanna Kim. 11:07:15
`
` I'm not related to any party in this
`
` action, nor am I financially interested in the
`
` outcome.
`
` Counsel and all present will now state
`
` their appearances and affiliations for the record. 11:07:22
`
`Veritext Legal Solutions
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`Page 6
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`Petitioner Samsung Ex. 1014
`Page 006
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` If there are any objections to proceeding,
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` please state them at the time of your appearance,
`
` beginning with the noticing attorney.
`
` MR. COOK: This is Brian Cook. I'm with
`
` O'Melveny & Myers representing the Petitioners, 11:07:33
`
` Samsung Electronics Company and Samsung Electronics
`
` America.
`
` MR. RUBIN: This is Neil Rubin of Russ
`
` August & Kabat, representing the Patent Owner Solas
`
` OLED Limited and defending the witness. 11:07:48
`
` THE VIDEOGRAPHER: Thank you.
`
` Will the court reporter please swear in
`
` the witness.
`
` THOMAS CREDELLE,
`
` having been duly administered an oath over
`
` videoconference as stipulated by all counsel, was
`
` examined and testified as follows:
`
` EXAMINATION
`
` BY MR. COOK:
`
` Q. Good morning.
`
` Could you please state your name for the
`
` record.
`
` A. Yes. This is Thomas Credelle. 11:08:21
`
`Veritext Legal Solutions
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`Page 7
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`Petitioner Samsung Ex. 1014
`Page 007
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` Q. And, Mr. Credelle, have you been deposed
`
` before?
`
` A. Yes.
`
` Q. About how many times?
`
` A. I've lost count, but it's 20 or 30 at 11:08:32
`
` least.
`
` Q. Okay. Have you been deposed by
`
` videoconference before like we're doing now?
`
` A. Yes. During the last two years, almost
`
` exclusively. 11:08:50
`
` Q. Okay. So you're familiar with the
`
` deposition process generally?
`
` A. Yes.
`
` Q. So even though we're taking this
`
` deposition remotely, you understand that you're 11:08:58
`
` under oath to tell the truth under penalty of
`
` perjury?
`
` A. I do.
`
` Q. And as we have a reporter here today
`
` taking down everything we say, it's important not 11:09:08
`
` to talk over one another.
`
` Do you understand that?
`
` A. Yes. Yes.
`
` Q. Where are you located today?
`
` A. I'm in Powell Butte, Oregon. 11:09:17
`
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`Page 8
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`Petitioner Samsung Ex. 1014
`Page 008
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` Q. And is that at your home?
`
` A. Yes, it is.
`
` Q. Okay. Is there anybody else in the room
`
` there with you?
`
` A. No, there's not. 11:09:30
`
` Q. Do you have any electronic devices in the
`
` room with you, other than the computer that you're
`
` using for the remote deposition?
`
` A. I do. My cell phone is in the room. It's
`
` on mute. I can remove it if you'd like, but it's 11:09:44
`
` in the room.
`
` Q. Okay. That -- that's fine just as long as
`
` you understand you're not -- not to use that cell
`
` phone to communicate with anyone during the
`
` deposition. 11:09:57
`
` A. Yes, I agree.
`
` Q. Okay. Do you have any documents in the
`
` room with you?
`
` A. Yes. I did print out two or three of the
`
` documents that I found facilitate these kind of 11:10:07
`
` depositions.
`
` I have my report printed, no -- no
`
` notations on it. I have Mr. Hatalis's report. I
`
` have the '880 patent and the Miyazawa patent
`
` printed it out. 11:10:19
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`Page 9
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`Petitioner Samsung Ex. 1014
`Page 009
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` I didn't print out Morosawa. It's too
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` big.
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` So the other ones, we could use the
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` electronic version.
`
` Q. Okay. And none of those documents have 11:10:29
`
` any markings or notations on them?
`
` A. That's correct.
`
` Q. Okay. And any other documents, any notes
`
` or anything with you?
`
` A. No other documents on my desk or nearby. 11:10:42
`
` Yes, they're all put away. Other documents are in
`
` drawers and not -- not accessible.
`
` Q. Okay. So did you submit a declaration on
`
` behalf of Solas OLED Limited in IPR2021-'591?
`
` A. Yes, I did, I believe in January. 11:11:03
`
` Q. Okay. So I've uploaded to the Exhibit
`
` Share or you can use the one in front of you, I
`
` have a copy of Exhibit 2001 previously marked in
`
` this case.
`
` (Previously marked Deposition Exhibit 2001 11:11:18
`
` was referenced.)
`
` Do you recognize that as your declaration
`
` that you submitted in this case?
`
` A. 2001, yes, that's my declaration.
`
` Q. And in Exhibit 2001, could you flip to the 11:11:30
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`Page 10
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`Petitioner Samsung Ex. 1014
`Page 010
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` end there, page 97.
`
` A. Okay. Yes.
`
` Q. And on page 97, is that your signature?
`
` A. Yes, it is.
`
` Q. Okay. Did you write this declaration? 11:12:04
`
` A. Yes, I did.
`
` Q. Okay. Did you -- did anybody help you
`
` with writing the declaration, or you did it
`
` yourself?
`
` A. It was a collaboration with the attorneys 11:12:18
`
` at -- at the law firm.
`
` Q. Are there any opinions in this declaration
`
` that you disagree with?
`
` A. Not that I can recall. I think it's my
`
` opinion. 11:12:40
`
` Q. And are all of your opinions in this case
`
` included in this declaration?
`
` A. All -- all of my opinions relative to the
`
` '880 IPR are included in this document.
`
` Q. Okay. So this -- this declaration's a 11:13:00
`
` complete statement of your opinions in this -- in
`
` this IPR?
`
` A. It's a statements of my opinions that I
`
` recorded in this document, correct.
`
` Q. And it -- it's a complete statement of 11:13:09
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`Page 11
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`Petitioner Samsung Ex. 1014
`Page 011
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` your opinions in this case?
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` A. When you say "complete," I -- I have --
`
` have other opinions about aspects of the -- of the
`
` patent in the case, but these are the ones --
`
` these -- what's in the report is what I -- I wrote 11:13:24
`
` in support of this IPR.
`
` Q. And -- and the other opinions that you're
`
` referring to, why are they not in your
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` declaration?
`
` A. Because I didn't feel they were necessary. 11:13:35
`
` Q. Okay.
`
` THE COURT REPORTER: Counsel, this is the
`
` court reporter. May we go off the record for an
`
` audio adjustment, please.
`
` MR. COOK: Yes. 11:13:55
`
` MR. RUBIN: That's fine.
`
` THE VIDEOGRAPHER: We are off the record
`
` at 11:14 a.m.
`
` (Off the record.)
`
` THE VIDEOGRAPHER: We are on the record at 11:17:53
`
` 11:17 a.m.
`
` BY MR. COOK:
`
` Q. Okay. So, Mr. Credelle, we were just
`
` discussing that you had a couple of additional
`
` opinions, but that you didn't feel that they were 11:18:12
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`Page 12
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`Petitioner Samsung Ex. 1014
`Page 012
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` necessary.
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` Do you still feel that those additional
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` opinions are not necessary to your opinion?
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` MR. RUBIN: Objection. Form.
`
` THE WITNESS: Basically my -- my opinions 11:18:21
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` are captured in this document.
`
` BY MR. COOK:
`
` Q. Okay.
`
` Can you turn to page 6 of your
`
` declaration? There's a heading called "MATERIALS 11:18:31
`
` CONSIDERED"?
`
` A. Yes, I see that.
`
` Q. Does this -- is this a list of all the
`
` materials you considered in forming your opinion
`
` in this case? 11:18:55
`
` A. Let me review quickly.
`
` I don't see reference to the prosecution
`
` history, but I did review that as well. Maybe I
`
` left that out.
`
` Q. Okay. 11:19:22
`
` So you reviewed Dr. Hatalis's declaration?
`
` A. Correct.
`
` Q. And you reviewed all of the prior art that
`
` Dr. Ha- -- Dr. Hatalis opined on in his
`
` declaration? 11:19:39
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`Page 13
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`Petitioner Samsung Ex. 1014
`Page 013
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` A. I did.
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` Q. Are you aware of any errors in your
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` declaration that you need to correct?
`
` A. I'm not aware of any.
`
` Q. Now, did you also give testimony recently 11:19:44
`
` before the International Trade Commission
`
` regarding the '880 patent?
`
` A. Yes, I did.
`
` Q. And was that in Investigation Number
`
` 337-TA-1243, Certain Active Matrix OLED Display 11:20:04
`
` Devices and Components Thereof?
`
` A. Yes.
`
` Q. Okay.
`
` MR. COOK: I've uploaded a -- an exhibit
`
` that I've marked as Exhibit 1013. 11:20:22
`
` (Credelle Deposition Exhibit 1013 was
`
` marked electronically.)
`
` THE WITNESS: Okay.
`
` BY MR. COOK:
`
` Q. Would you let me know when you have that 11:20:27
`
` opened up?
`
` A. I have it on my screen.
`
` Q. Do you recognize Exhibit 1013 as the
`
` public version of your trial testimony from the
`
` '1243 ITC investigation? 11:20:38
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`Page 14
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`Petitioner Samsung Ex. 1014
`Page 014
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` A. I did read it, and I see that it is
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` public, and it at least is a portion of my
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` testimony. I don't think it's the entire public
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` portion.
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` Q. Is it the entire portion that deals with 11:20:48
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` the '880 patent?
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` A. That -- to that I'm not certain. This was
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` provided to me. I -- I've read it, recognize it.
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` But I don't know if it's all of the testimony
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` regarding the '880. 11:21:05
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` Q. Now, in the ITC trial, you did not testify
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` regarding validity of the '880 patent; is that
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` correct?
`
` A. That's correct.
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` Q. Okay. 11:21:16
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` I'd like to turn back to your declaration
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` again for a minute, Exhibit 2001.
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` A. Okay.
`
` Q. Now, in -- in analyzing the claims of the
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` '880 patent in the context of this IPR, did you 11:21:33
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` apply the plain and ordinary meaning to all claim
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` terms?
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` A. Yes, I did.
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` Q. And let's turn to page -- or, sorry,
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` paragraph 69 of your declaration. 11:21:58
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` A. Yes, I see the reference to the ITC claim
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` construction.
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` Q. Okay. And at paragraph 69, you say, "In
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` his declaration, Dr. Hatalis assumes that each
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` term of the '880 patent is to be given its plain 11:22:29
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` and ordinary meeting. Unless otherwise noted, I
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` apply the" -- "I apply the claims of the '880
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` using their plain and ordinary meaning in this
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` declaration." [As read]
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` Do you see that? 11:22:43
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` A. I see that.
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` Q. Okay. Was there any place in your
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` declaration that you -- where you noted that you
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` did not apply -- or you applied some other meaning
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` other than the plain and ordinary meaning? 11:22:54
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` A. Not to my recollection. But as I state in
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` paragraph 71, my opinions would be the same even
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` if these ALJ constructions that I listed on page
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` 28 and 29 were applied.
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` Q. Okay. So in -- the ALJ constructions 11:23:11
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` you're referring to are the -- are the terms as
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` construed by the ALJ in the ITC case?
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` A. Correct.
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` Q. Okay. And you stated, as you noted in
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` paragraph 71, that your opinions would also apply 11:23:27
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` if any of those ITC constructions were adopted by
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` the PTAB?
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` A. That's correct.
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` Q. Okay. So did you apply the -- ITC's
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` constructions, or did you apply -- apply plain 11:23:43
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` meaning?
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` A. I applied the plain meaning, which I think
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` lines up well with what the ALJ, you know,
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` concluded about various terms.
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` Q. Mm-hmm. 11:23:59
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` So did you conclude that there was no
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` difference between plain meaning and the
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` constructions the ALJ adopted in the related ITC
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` case?
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` A. I didn't see any major distinctions 11:24:12
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` between the two that affected my opinion.
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` (Interruption in audio/video.)
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` THE COURT REPORTER: One second, please.
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` THE WITNESS: Something happened here to
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` my -- oh, excuse me one minute. 11:24:32
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` For some reason, my tablet woke up, and
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` I'm going to mute it. I apologize for that.
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` BY MR. COOK:
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` Q. Okay. No problem.
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` A. Hopefully that won't happen again. 11:24:55
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` Q. Okay. No problem.
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` A. The sound is off, too.
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` Okay. I'm sorry.
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` Q. Okay. So are you ready? All right.
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` So, in other words, for the purposes of 11:25:14
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` applying the prior art in this IPR to the claims
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` of the '880 patent, you've concluded that there's
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` no appreciable difference between whether --
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` between applying the plain meaning or applying the
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` constructions from the ITC case. 11:25:30
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` Is that a fair statement?
`
` A. Yes.
`
` Q. Okay.
`
` Do you have Exhibit 1001 -- that's the
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` '880 patent -- there in front of you? It's also 11:25:43
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` uploaded to the Exhibit Share.
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` (Previously marked Deposition Exhibit 1001
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` was referenced.)
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` A. Yes, I do.
`
` Q. Okay. I'd like to start by turning to 11:25:49
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` page -- or, sorry, turning to Figure 10. And let
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` me know when you have that in front of you.
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` A. Okay.
`
` Q. So do you understand Figure 10 to depict
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` a -- a -- a claimed embodiment of the alleged 11:26:12
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` invention?
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` A. Yes, that's my understanding.
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` Q. And Figure 10 is a schematic
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` representation of the display panel?
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` A. The display panel, including various 11:26:24
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` drivers attached to the panel, depending on how
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` you define "the panel."
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` Q. Okay. So Figure 10 includes boxes
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` representing various functional blocks?
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` A. Yes. 11:26:44
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` Q. Like the data driver, for example, the
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` scanning driver, and so forth?
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` A. That's correct.
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` Q. Okay. And Figure 10 also includes symbols
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` and arrows representing connections between the 11:26:57
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` functional blocks?
`
` A. Yes, it does.
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` Q. Does Figure 10 depict the layout of the
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` pixels on the display?
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` A. It does not from a layout perspective. 11:27:10
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` Q. Does Figure 10 depict the location of
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` pixels relative to other structures?
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` A. Figure 10 shows a box labeled "EM," which
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` is the display circuit attached to various inputs
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` and outputs -- I should say inputs only, shown by 11:27:31
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` vertical and horizontal lines coming from the data
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` driver or scan drivers and power supply, other --
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` other functional blocks.
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` Q. And -- and does it depict the location of
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` those pixels relative to other structures? 11:27:50
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` A. It shows schematically their location.
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` Q. And what do you mean by "it shows
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` schematically their location"?
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` A. It shows a block which, I believe in
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` the -- in the patent, describes is the circuitry, 11:28:05
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` for example what's on page 11 -- or Figure 11,
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` being in the -- the location of various connecting
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` lines drawn as vertical and horizontal lines on
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` this -- on this page.
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` Q. So Figure 10 shows that the pixels are 11:28:25
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` connected to the horizontal and vertical lines you
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` just mentioned?
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` A. Yes. And -- and in terms of an electrical
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` schematic, they are shown connected with a small
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` black circle. 11:28:45
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` Q. And does Figure 10 provide a distance
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` between pixels and intersections of the data and
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` scanning lines?
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` A. Not on this schematic, it does not.
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` Q. Does the patent anywhere provide distance 11:28:53
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` between the pixels and the loca- -- and the
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` intersections of data and scanning lines?
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` A. I don't recall if it said the resolution
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` of the display example. I don't recall any
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` dimensions in the patent specifically. 11:29:10
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` Q. Does -- does -- does Figure 10 indicate
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` that the pixels are located entirely within the
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` areas defined by the intersections of the data and
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` scanning lines?
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` A. It -- it doesn't really indicate that. It 11:29:25
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` shows a set of transistors connected, as I
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` mentioned, to the various vertical and horizontal
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` lines.
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` Q. Do you understand that to be the case even
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` though it doesn't specifically say that? 11:29:44
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` A. I understand that the box labeled "EM,"
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` there's one box for every vertical data line and
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` for every group of three horizontal lines as
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` depicted in Figure 10.
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` Q. Can we turn to -- to, let's see, column 3, 11:30:04
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` line 40.
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` A. Okay. Would you like me to read the whole
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` paragraph, or do you want to ask a question?
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` Q. No, we don't need to read it.
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` Taking a look at that paragraph, do you 11:30:36
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` see -- did you see in there that it discusses
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` pixels arranged in vicinities of intersections of
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` scanning lines and data lines?
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` THE COURT REPORTER: Excuse me. Counsel,
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` could you slow down just a little bit please and
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` repeat that.
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` MR. COOK: Sure. I'm sorry.
`
` BY MR. COOK:
`
` Q. Yeah, in -- in that paragraph that starts
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` at -- at line 40, do you see a reference to 11:30:50
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` display pixels arranged in vicinities of
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` intersections of the scanning lines and data
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` lines?
`
` A. Yes, I see that passage.
`
` Q. How did you interpret the term 11:31:05
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` "vicinities" in your analysis?
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` A. I think vicinities, in my analysis, means
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` in the vicinity of. It means near -- could be
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` nearby or as -- even as the ALJ suggested,
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` proximity to those intersections. But, to me, 11:31:28
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` it's a plain and ordinary meaning.
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` Q. So vicin- -- and "vicinities of" could
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` mean near, for example?
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` A. It -- it could mean near with the
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` qualification that each -- well, each set of 11:31:40
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` transistors is -- is -- is between various lines,
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` as shown in the schematic. So I wouldn't say that
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` the last pixel is near the first pixel, but it's
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` near -- it's -- they're near adjacent pixels.
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` Q. Okay. And you mentioned the ALJ's 11:32:01
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` construction. Is -- is there a difference between
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` "near" and "in proximity to"?
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` A. Not -- not really in my opinion. They're
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` very similar.
`
` Q. I've -- I've put Exhibit 1008 in Exhibit 11:32:14
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` Share, which is the Morosawa reference.
`
` (Previously marked Deposition Exhibit 1008
`
` was referenced.)
`
` A. Okay.
`
` Q. Let me know when you have that open. 11:32:39
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` Do you recognize this exhibit, 1000- --
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` 1008 as the Morosawa reference?
`
` I'm sorry, I didn't quite hear that.
`
` A. Yes, I do.
`
` Q. Oh. Thank you. 11:32:58
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` Did you analyze the Morosawa reference in
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` preparing your declaration?
`
` A. I did.
`
` Q. I'd like you to turn to page 2 of Morosawa
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` and take a look at the paragraph that begins on 11:33:16
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` line 16.
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` A. Page 2 of the patent? Okay, I got it.
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` Q. So I'll just read, the -- the
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` paragraphs -- the -- the sentence starting on line
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` 16 says, "This particular type of display panel, 11:33:46
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` briefly, is" -- or "is comprises an array of
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` display pixels which contain light emitting
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` elements arranged near each of the intersecting
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` points of the signal lines and in the direction of
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` the scanning lines set in the line writing 11:34:04
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` direction;"
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` Do you see that?
`
` A. I see that.
`
` Q. Did you -- did you consider that
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` disclosure in Morosawa when you reached your 11:34:13
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` conclusions about whether Morosawa discloses
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` pixels arranged in the vicinity of intersections?
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` A. I -- I did consider that, and -- and I
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` expressed my opinions in my report as you, I'm
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` sure, have read. 11:34:28
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` Q. Okay. Let's turn to page 6, line 12.
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` And starting at line 12 Morosawa states,
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` "To achieve the foregoing advantage, the first
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` display device in the present invention comprises
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` a display panel with a plurality of signal lines 11:35:02
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` and a plurality of scanning lines which intersect
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` at right angles with each other, and a plurality
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` of display pixels with optical elements arranged
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` near the intersecting point of the plurality of
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` signal lines and the plurality of scanning lines;" 11:35:21
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` Did I read that correctly?
`
` A. Yes, you did. I -- I -- let me see.
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` Yeah, so this is referring to the optical
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` elements near the intersections, yes.
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` Q. And the optical elements are part of the 11:35:40
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` display pixel?
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` A. I don't recall actually the -- what
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` Morosawa defines optical elements. I can't recall
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` if it's just the organic --
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` (Interruption in audio/video.) 11:35:58
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` -- or if it's the transistors that drive
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` it.
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` THE COURT REPORTER: Excuse me. I can't
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` recall if?
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` THE WITNESS: I don't recall if Morosawa 11:36:00
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` describes all the optical element the organic
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` light-emitting material only, or it also included
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` the transistors that drive it.
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` BY MR. COOK:
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` Q. So on line 16 of page 6, it refers to -- 11:36:16
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` or line 15 and 16, I guess, it says "a plurality
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` of display pixels with optical elements arranged
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` near the intersecting points"? [As read]
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` A. Yes.
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` Q. Is that -- okay. 11:36:31
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` And how did -- how did you interpret --
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` did you interpret that sentence to say that only
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` the optical elements but not the display pixels
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` are arranged near the intersecting point?
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` A. As -- as I said, I -- I actually don't 11:36:44
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` recall precisely if the display pixel definition
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` in Morosawa includes the transistors that drive
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` the optical elements or the word "optical
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` elements" includes the transistors. I'm sure we
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` could look and find that, but I don't recall. 11:37:02
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` So at least it includes the optical
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` elements for sure within the display pixel. There
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` are other components which aren't listed here.
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` Q. Okay. Did you consider this -- this
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` disclosure here on page 6 in reaching your 11:37:21
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` conclusions about whether Morosawa discloses
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` pixels arranged in the vicinity of intersections?
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` A. I considered it.
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` Q. Okay. Let's turn to page 57 of Morosawa,
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` about line 23. 11:37:49
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` A. Okay.
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` Q. So line 23 is referring to Figure 16.
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` A. Okay.
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` Q. And starting on line 23, Morosawa says,
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` "As shown in Figure 16, the pixel driver circuits 11:38:08
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` DCx related to this example case has a
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` configuration on Nch transistor Tr71, an Nch
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` transistor Tr72, an Nch transistor Tr73 and a
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` capacitor Cx. In the pixel driver circuits DCx,
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` near the intersecting point in which the scanning 11:38:39
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` lines SL and the signal lines DL are arranged,"
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` and then it goes on from there.
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` A. Yes, I see that.
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` Q. So is that referring to pixel driver
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` circuits DCx that are near the intersections of 11:38:53
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` the scanning and data lines?
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` A. What it's describing schematically on
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` Figure 16 is -- is the circuit configuration, yes,
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` and is as schematically drawn near the
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` intersections of the vertical and horizontal lines 11:39:25
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` that is shown in Figure 16.
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` Q. And did you also consider this disclosure
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` here on page 57 in forming your opinions about
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` whether Morosawa discloses pixels arranged in the
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` vicinity of intersections? 11:39:46
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` A. It was considered, yes.
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` Q. Okay. I'd like to switch over to
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` Exhibit 1006.
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` (Previously marked Deposition Exhibit 1006
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` was referenced.) 11:40:01
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` THE WITNESS: Okay.
`
` BY MR. COOK:
`
` Q. Do you recognize Exhibit 1006 as the
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` Miyazawa reference?
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` A. Yes, I do.
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