`
`Transcript of Jianzhong Jiao, Ph.D.
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`Date: October 3, 2023
`Case: Volkswagen Group of America, Inc. -v- Spero (PTAB)
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
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` A P P E A R A N C E S
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`ON BEHALF OF PETITIONER:
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` JASON A. FITZSIMMONS, ESQUIRE
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` IAN SOULE, ESQUIRE (via Zoom)
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` JOHN D. HIGGINS, ESQUIRE
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` STERNE, KESSLER, GOLDSTEIN & FOX PLLC
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`VOLKSWAGEN GROUP OF AMERICA, INC., :
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` Petitioner, :
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` vs :
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`YECHEZKAL EVAN SPERO, :
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` Patent Owner. :
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` U.S. Patent No. 10,894,503 to Spero
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`Case Nos. IPR2023-00197, IPR2023-00328, IPR2023-00335
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`ON BEHALF OF PATENT OWNER:
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` Oral deposition of
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` SANGEETA G. SHAH, ESQUIRE (via Zoom)
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` JIANZHONG JIAO, PH.D.
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` WASHINGTON, DC
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` BROOKS KUSHMAN P.C.
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` 1000 Town Center
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` 22nd Floor
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` TUESDAY, OCTOBER 3, 2023
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`Job No.: 509471
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`Pages: 1 - 118
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`Reported by: Lisa V. Feissner, RDR, CRR, CLR
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` A P P E A R A N C E S (cont'd)
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`ON BEHALF OF PORSCHE AG and PCNA:
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` ROBERT E. COLLETTI, ESQUIRE (via Zoom)
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` HAUG PARTNERS LLP
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` 745 Fifth Avenue
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` New York, NY 10151
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` (212) 588-0800
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`held at the offices of:
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` 1101 K STREET, NW
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` Pursuant to Notice, before Lisa V.
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`Feissner, RDR, CRR, CLR, Notary Public.
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`ALSO PRESENT:
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
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` Also, if you need to take a break, please
`don't hesitate to let me know. I will say in
`advance, there's a chance that I may need to pause
`during this deposition because I -- as it turns out,
`I'm doing this not from my office, and there may be
`some background circumstances that arise that are
`outside of my control. So if that arises, I'll let
`you know.
` But other than that, please let me know
`if you have any questions, and if not, we can
`commence the deposition.
` A Okay.
` MR. FITZSIMMONS: And Sangeeta, this is
`Jason Fitzsimmons, Sterne Kessler. Just since the
`deposition is covering the three proceedings with
`three declarations, if you could try to just make
`clear for the record which proceeding or which
`claims we're referring to so that's clear, it would
`be helpful for the record.
` MS. SHAH: Absolutely. We'll try to do
`that if possible. Some of the issues are central to
`all of them. But to the extent we're referring to
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` C O N T E N T S
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`EXAMINATION OF JIANZHONG JIAO, PH.D. PAGE
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` By Ms. Shah 6
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` E X H I B I T S
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`specific testimony, we'll, of course, refer to, you
`know, a specific exhibit number for the ease of
`record, clarification.
` MR. FITZSIMMONS: Thanks. Appreciate it.
` Q So with that, let's go ahead and start
`with -- let me see here. Let's start with -- so I'd
`like to point your attention to the declaration that
`you submitted, Dr. Jiao, in the IPR 2023-00197
`proceeding. If you can -- do you have access to
`that declaration? It's Exhibit Number 1003.
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` A Okay.
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` Q Okay. So my first question is, if you
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`look at the table of contents, you'll see that there
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`are -- well, actually -- yeah. So you'll see in the
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`table of contents of your declaration that there's a
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`series of grounds that are listed.
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` A Yes.
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` Q You see that?
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` So can you identify for me how many
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`grounds exist in this that you opined on (inaudible)
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`declaration?
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` A Six.
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` P R O C E E D I N G S
` JIANZHONG JIAO, PH.D.,
`having been first duly sworn, was examined and
`testified as follows:
` EXAMINATION
`BY MS. SHAH:
` Q Good morning, Dr. Jiao. How are you
`today?
` A Good morning. Good. How are you?
` Q Good. I'm glad we worked out our
`technical issues so that we could commence our
`deposition.
` So my first question -- I did want to
`just briefly state, of course, as we go through
`these deposition process, if you have any questions,
`please feel free to stop me to ask the question.
` If you don't understand a question that I
`pose, please, once again, ask me to clarify the
`question or -- you know, I want to make sure that
`you're able to answer all the questions that I pose
`today, (inaudible) so you understand the questions
`that I'm asking you.
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
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` Q And let's go to -- let's jump to
`paragraph 126 of that Exhibit 1003.
` A I'm here.
` Q You're there? Okay, great.
` So the question I wanted to ask you is,
`with respect to the statement that you have in
`paragraph 126, can you explain to me that when
`Beam -- the Beam reference discusses blanking, does
`that also include dimming?
` MR. FITZSIMMONS: Objection, form.
` A Can you point to me where in my
`declaration that I stated that such function?
` Q One second. Well, let's look first at
`paragraph 173 where you discuss -- well, go ahead.
`Let's look at paragraph 173.
` A You said paragraph 173?
` Q Yes.
` A Okay.
` Q So do you see the language in paragraph
`173 that refers to blanking?
` A Yes.
` Q And is it your understanding that in
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` A What I said is, the reduced in intensity
`is an area identified by this reference as blanked
`area.
` Q Okay. So I'm sorry, just to clarify.
`When you say that an area is reduced in intensity,
`you are pointing to the areas that are blanked.
` Is that correct?
` A I point to the area to where I quoted the
`language, blanked area tracks location of oncoming
`vehicle. That's where intensity is reduced.
` Q What is your understanding within Beam of
`the term "blanking"?
` MR. FITZSIMMONS: Objection, form.
` Q So, for example, as provided in paragraph
`173 where you refer to blanked areas, what is your
`understanding of how that term is used in the Beam
`reference?
` MR. FITZSIMMONS: Objection, form.
` A It's exactly what the phrase is used in
`my declaration. That's the area that tracks
`location of oncoming vehicle, for instance. That's
`the area.
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`Beam, when they refer to blanked areas or blanking,
`that that also includes dimming?
` MR. FITZSIMMONS: Objection, form.
` A My understanding is exactly stated in my
`declaration using the quotation of the language that
`this reference stated.
` Q I'm sorry. Can you point to me what your
`position is with respect to the question that I
`posed?
` A My position is, the blanked area tracks
`location of oncoming vehicle. That's the area, the
`blanked.
` Q Okay. So the question that I asked is,
`when Beam is referring to blanking an area, is it
`your understanding that blanking includes the
`concept of dimming?
` A What I stated is using the description of
`such reference with the statement of phrase called
`reduced in intensity.
` Q Okay. So then is it accurate to say that
`in your view, when Beam talks about blanking, that
`also includes reducing intensity?
`
` Q Okay. I'm sorry. I'm not asking you
`about a blanked area.
` I'm asking, in the Beam reference, when
`this concept of blanking is discussed, technically,
`can you explain to me how blanking is achieved?
` MR. FITZSIMMONS: Objection, form.
` A I'm sorry. I didn't understand what the
`phrase, how the blanking is achieved. What I stated
`here is, he defined -- there are certain area, when
`it track the vehicle, that area is called a
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`blanked -- that area is a blanked area. That's the
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`determination.
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` So I didn't understand your question,
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`achievement question.
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` Q Okay. So let's look at paragraph 184.
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`Let me know when you're there.
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` A I am there.
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` Q So with respect to paragraph 184, there
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`is this -- in quotations, there's language about the
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`outputs blanking signals, and then it continues on
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`with commands the appropriate pixels to be reduced
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`in intensity.
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
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` Do you see that?
` A I do.
` Q So with respect to the idea of blanking
`the signal, what is it that happens with respect to
`the blanking of signal in the Beam reference?
` MR. FITZSIMMONS: Objection, form.
` A As I stated in my declaration, Beam
`disclosed the spatial sense data detected from the
`sensor and becomes the input to determine the
`so-called blanking area.
` Q And as you state here, where you say, The
`processor used appropriate algorithms on incoming
`data to determine the locations to be blanked,
`output blanking signals commands the appropriate
`pixels to be reduced in intensity.
` Part of what I'm asking -- so once again,
`here when it says output blanking signals and
`commands the pixels to be reduced in intensity, but
`reduced in intensity is referring to the blanking
`signals that are output.
` Is that correct?
` A Reduce the signal is based on the
`
`asking is, if there is a reduction in intensity --
`well, actually, let me clarify.
` For the blanked area, is there no light
`provided?
` A My response to that, I believe in my
`declaration, I described -- I referred to what this
`reference disclosed, and whether it is reduced
`intensity or to zero.
` Q Okay. So can you point to me where in
`the Beam reference there is a disclosure of blanking
`as something other than zero?
` A In paragraph 184, to be reduced in
`intensity, reduced is less. It didn't say zero.
`Yet I'm pretty sure in my declaration I referred to
`Beam disclosed that reduction can be off, like zero.
` Q I see. So "reduced in intensity" means a
`reduction from maximum intensity to zero. That's
`the reduction in intensity that you're referring to?
` MR. FITZSIMMONS: Objection, form.
`Objection, mischaracterizes the witness's testimony.
` A What I said is, in paragraph 184, I
`reference to the statement "reduce in intensity."
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`detection, in paragraph 184, spatial data detected
`by the sensor 107 and processor calculate that
`sensing -- sensed information to determine the
`blanked area or select the area to be dimmed, to be
`reduced for intensity.
` Q And when you refer to "blanked area,"
`what does that mean?
` A Again, it is described in the reference
`in that the entire projected lights were coming from
`these microbeams, the light source of microbeams, in
`a discrete manner, and the sensoring information can
`determine which microbeam additively as the blanked
`area need to be reduced in intensity.
` Q So is there a reduction in intensity, or
`is no light provided to the blanked area?
` A I remember I disclosed this in my
`declaration, that described by Beam.
` Q I'm sorry. Can you point -- can you
`point where the answer to my question is in your
`declaration?
` A I can take a look.
` Q So just to clarify, the question that I'm
`
` What I also said in my declaration, I
`recall that Beam also disclosed to reduce to zero.
` Q Okay. Do you see those as two different
`things, reduce in intensity and reduce to zero?
`When you say -- in paragraph 184, when you're
`referring to reduce in intensity, and you're talking
`about Beam disclosing reducing to zero, are they two
`different things in the context of paragraph 184?
` MR. FITZSIMMONS: Objection, form.
` A In my understanding, reduced in intensity
`0
`is from one value to be below that value. My
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`understanding of zero is to give a quantitative
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`result of a reduced intensity.
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` Q Okay. So in paragraph 184, when there's
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`the statement here about the dimmed area --
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` Do you see that?
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` A Yes.
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` Q -- is that a zero value?
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` A Dimmed area is corresponding to the
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`blanked area to be reduced in intensity.
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` Q Can you to go to paragraph 117 of your
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
`17
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` A I'm here.
` Q Do you see the first sentence that
`states, Though it is in my opinion that Beam
`explicitly or implicitly discloses every feature
`recited in claims 20, 24, 25?
` A Yes, I saw it.
` Q What is your understanding of the
`difference between explicitly or implicitly in that
`sentence?
` A Do you want me explain the legal
`definition? I'm not a lawyer.
` Q What's your understanding of the
`difference between those, if you have a legal
`understanding, but really more just in the context
`of what's written there.
` A Well, based on the person of ordinary
`skill in the art, my understanding is "explicitly"
`means more directly. "Implicitly" means maybe
`indirectly or can be interpreted to.
` Q But do you have an understanding of those
`words as tied to any legal principles?
` A Legal principle in regarding to?
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`5 (17 to 20)
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` Q Okay. So are those terms -- based on
`your reading of the legal doctrine of anticipation,
`does -- when it's your opinion that Beam explicitly
`discloses every feature, is that tied to the
`doctrine of anticipation?
` MR. FITZSIMMONS: Objection, form.
`Objection, calls for a legal conclusion.
` A I thought my declaration is -- described
`obviousness.
` Q Okay. So it's your understanding, then,
`that the sentence that it's your opinion that Beam
`explicitly or implicitly discloses every feature is
`related to the issue of whether Beam -- whether it's
`obvious from the Beam reference -- whether all the
`features of claims 20, 24, and 25 are obvious in the
`Beam reference?
` MR. FITZSIMMONS: Objection, form.
` A Again, my declaration is -- my
`declaration is to support an argument for
`obviousness, which is based on my understanding of
`paragraph -- starting from paragraph 31.
` Q Okay. Looking at paragraph -- continuing
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` Q Like, for example, are you familiar with
`the idea of -- the legal principle -- the -- what is
`referred to as anticipation, the doctrine of
`anticipation? Are you familiar with that doctrine?
` A I stated in my declaration for my
`understanding. I can go back to read it.
` Q Okay. Go ahead, and if that would help
`you to answer the question, feel free to look at it.
` A I wrote in paragraph -- starting from
`paragraph 33 on page 12 for my understanding of
`obviousness. Do you want me to read the section?
`That's my understanding.
` Q I just wanted you to go ahead and refresh
`your recollection. If you would like to read it out
`loud, that's also fine. I just wanted to make sure
`that to the extent you included language about your
`understanding of anticipation, you had an
`opportunity to review it just now.
` A As I read, the understanding of
`obviousness is based on the disclosure prior arts.
`Again, "explicitly" for me is more directly.
`"Implicitly" means maybe indirectly.
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`on to the next paragraph, paragraph 118. Can you --
`go ahead and take a look at paragraph 118. I have
`some questions about paragraphs 118 and 119.
` A Okay.
` Q Can you specifically identify what
`hardware you're referring to in paragraph 118?
` A In paragraph 118, I identified light
`source is the microbeam that is the combination of
`hardware lamp 202 and spatial light modulator 203.
` Q Okay. And then when we go to paragraph
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`119, can you point to the specific hardware that
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`you're relying on for paragraph 119.
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` A In paragraph 119, I described the
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`comparison of two embodiments, which both disclosed
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`light source. Embodiment 1 is 202 combining with
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`203. Embodiment 2 is combined function in -- oh,
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`I'm sorry. In -- I didn't see the figure. But in
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`the light source, embodiment 2 is element 401, which
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`is in Figure 4.
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` Q Okay. I'm sorry. You were indicating
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`that the one embodiment is the lamp 202 and another
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`embodiment is the array of light sources 401.
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
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`Beam's -- disclosure Exhibit 1005 in column 3, 61-64
`in my paragraph 119. I can go back to each column
`to re-review what is -- the specification the
`disclosure described.
` Again, it is my understanding that Beam
`disclosed light source as such, that is, a
`combination of emitter and spatial light modulator
`as a microbeam.
` Q So in paragraph 118, in the second
`sentence, when you say, Each microbeam is a
`directional "source," why did you put the word
`"source" in quotes?
` A Well, that's the statement. Each
`microbeam is a light source. Only here emphasizes
`directional light source as Beam disclosed is
`independently control its spatial, and we use the
`word "spatial" or "angular distribution." When you
`have light emission that being able to control to
`angularly or spatially, that is directional.
` Q Can you go to paragraph 77, please.
` A I'm here.
` Q Okay. So if you see in the second
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` Is that what you were referring to?
` MR. FITZSIMMONS: Objection, form.
` A No. What I said is, in paragraph 119,
`that I described two embodiments from Beam to
`disclose light source, namely, microbeams.
` Embodiment 1 is illustrated with two
`elements, 202, 203. Embodiment 2 is illustrated
`with one combined element 401. That's -- that's
`what's stated in my declaration 119.
` Q So in the second embodiment that includes
`the light source 401, is there an SLM? Is there a
`spatial light modulator?
` A Light source 401, as illustrated, it is
`microbeam. The definition or description microbeam
`includes emitter, whether it's lamp or LEDs, and
`spatial light modulator, which is optical element.
` So whether it's separate in Figure 2 or
`combined in Figure 4, Beam consistently described
`the light source, namely, microbeam, that it
`comprised with two elements, emitter and optical
`elements, namely, spatial light modulator.
` Q Okay. So it's your position that a
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`microbeam is a light source?
` A It is my position that Beam disclosed
`light source that is named as microbeam.
` Q Can you point to me where in the Beam
`reference Beam discloses light source as a
`microbeam?
` A It is in my declaration. I can go back
`the entire reference and to point out. The
`microbeam is what's used as his invention -- his
`disclosure as light source.
` Q If you could point to me specifically
`where in your declaration or in the Beam
`reference -- actually, if you can point to your
`declaration that identifies where in the Beam
`reference light source is named as a microbeam.
` A The first part that -- in my declaration,
`paragraph 118, I stated the combination of -- I
`stated that microbeam is a directional light source
`that I reference to Exhibit 1005 for column 4,
`26-29, and column 3, 30-21 [sic], and a bunch of
`figures.
` In addition, I also referred to the
`
`sentence of paragraph 77, you have the term
`"blanked" immediately followed by "(attenuated)."
` A I'm sorry. Paragraph 177?
` Q No, sorry. 77. Just 77, not 177.
` A I'm sorry. Can you repeat your question?
`I'm here, I just read paragraph 77.
` Q Yes. So in the second sentence of
`paragraph 77 --
` A Yes.
` Q -- when you say, Rays from lamp 202 fall
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`on and are reflected or blanked (attenuated), are
`11
`you equating "attenuated" with "blanking"?
`12
` A "Attenuated," POSA's understanding,
`13
`including me, it means reduced. Attenuation is
`14
`reduction of transmission or reduction of emission.
`15
` Q Okay. And so in this context, blanking
`16
`is attenuation?
`17
` A What I said, again, is the light ray from
`18
`lamps, as described by Beam, they're going to hit
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`the spatial light modulator, which served two
`20
`functions, reflected or attenuated.
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` Q When it serves the function of
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`Conducted on October 3, 2023
`25
`
`attenuation, does light escape the lamp?
` MR. FITZSIMMONS: Objection, form.
` A Spatial light modulator is a modulation
`device to the light or light ray that serves
`function of reflection attenuation.
` Q I'm sorry. I just wasn't clear. Is it
`reflection attenuation, or reflection or
`attenuation?
` A Both.
` Q Okay.
` A Can be both.
` Q And how is that achieved by a spatial
`light modulator? If you can start off by explaining
`to me how a spatial light modulator reflects light.
` MR. FITZSIMMONS: Objection, form.
` A I believe I described -- disclosed in my
`declaration that uses description in Beam
`specification and his claims.
` Q Can you point to me where that is in your
`declaration?
` A I can go back to look.
` Well, in paragraph 76, I refer to
`
`7 (25 to 28)
`
`27
`
` A Well, my declaration -- paragraph 119, I
`refer to several -- part of the reference,
`Exhibit 1009, column 3, 61-64; column 5, 3-16. And
`there is a few indicators in the reference -- the
`Beam reference. If you want, I can go back to the
`reference to look at each column and give you the --
` Q If you could go through and identify
`where in Beam there is a teaching that the LED
`embodiment combines the spatial light modulator.
`I'm sorry. From a given -- all the references you
`identified in your declaration, if you could point
`to which of those references supports the position
`that the LED embodiment includes the spatial light
`modulator.
` A One of them is column 8, Exhibit 5, from
`4 to 17, wherein it said, Light source include a ray
`of individual independently controllable microbeam
`source -- here's also your first question, the light
`source is microbeam source -- selected from a group
`of consists of light-emitting diodes, lasers, and
`others, and spatial light modulator.
` So this is explanation, microbeam is
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`26
`Exhibit 1005 at column 3, 8-44, and column 6, 53
`to 7- -- 6:53 to column 7:13. Let me see.
`There's -- and also, in paragraph 77, I refer to
`Exhibit 105, which is Beam's disclosure, column 4,
`26-59.
` I think in these disclosures in Beam's
`specification and claims, it explained how light
`spatial modulator works.
` Q You mentioned in paragraph 119 that there
`was comparison of embodiments.
` A What I stated is -- in paragraph 119 is,
`besides first embodiment, additionally, Beam
`disclosed the second embodiment, which light is
`generated from LED rather than non-LED.
` Q Does the LED embodiment include the
`spatial light modulator?
` A The second embodiment is the LEDs, the
`light emitted from solid-state emitter combining
`with spatial light modulator.
` Q Can you identify for me where in Beam the
`second embodiment, which is the LED embodiment,
`combines the spatial light modulator?
`
`emission and modulation combined.
` Also, column 5, number 3-6, in -- 202 and
`203 are replaced by 401. My understanding is
`combined into one.
` Q So it's your understanding that if
`something is replaced by, it's combined with?
` A It is my understanding in this particular
`description, by looking at his specification as well
`as Figure 4 and 6 and his claim 4, that the light
`source must include both emitter and spatial light
`0
`modulator, especially if you look at Figure 6. And
`11
`Figure 6 is alternative Figure 5. You have to have
`12
`a modulator in order to work as microbeam.
`13
` Q I'm sorry. Can you explain to me -- you
`14
`just mentioned that Figure 6 is an alternative to
`15
`Figure 5 and that you have to have the modulator in
`16
`order to work as a microbeam.
`17
` Can you explain that conclusion that you
`18
`just drew?
`19
` MR. FITZSIMMONS: Objection, form.
`20
` A Figure 6 is second or alternative
`21
`embodiment from Figure 5. Both disclose microbeam
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`Conducted on October 3, 2023
`29
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`8 (29 to 32)
`
`31
`region is part of motivations to combine because
`that may make the software design easier.
` Q In paragraph 126, is the software
`implementation in addition to the hardware
`implementation that's referred to in paragraph 125?
` MR. FITZSIMMONS: Objection, form.
` A I'm sorry. Can you point to me where in
`my declaration I state about hardware portion? I
`don't think it was 125.
` Q If you could take a look at 125. In
`paragraph 125, when you're referring to the building
`blocks --
` A Yes.
` Q -- would you describe that as hardware?
` A I described the hardware implementation
`in my declaration, paragraph 135.
` Q Okay. Let's go to paragraph 135.
` So when you have paragraph 135, that
`first sentence, when it says, Additionally or
`alternatively, a POSA would have sought to
`incorporate known components (hardware
`implementation), is that -- is the hardware
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`concept that is the individually controllable
`directional and intensity-wise light sources.
` Therefore, Figure 4 is -- I'm sorry --
`Figure 6 is alternative Figure 5. You have to have
`a way to emit light and to control the
`directionality and attenuation of the light.
` Therefore, a person of ordinary skill in
`the art would understand you have to have some way
`to modulate light. That's why they combined the two
`elements into one, namely 401.
` Q Now can you turn to paragraph 126 of your
`declaration.
` A I'm here.
` Q So you see the first sentence that says,
`First, including an additional or alternative
`control technique (software implementation) for
`Beam?
` A Yes.
` Q Can you describe for me how the
`additional control technique for Beam functions.
` MR. FITZSIMMONS: Objection, form.
` A I'm sorry. Additional control function?
`
`30
`Addition to Beam or from Beam? I didn't understand
`implementation being added to the software
`the question.
`implementation that is described in the preceding
`paragraphs?
` Q Well, if you can explain to me what that
` A What I describe in my declaration, for
`sentence specifically says, including an additional
`motivations to combine, I happened to described in
`or alternative control technique for Beam.
`two scenarios -- two aspects, the software aspect,
` Let's start off with, what is the
`which is starting from paragraph 131, and hardware
`additional control technique?
`aspect starting from paragraph 135.
` A I stated in my declaration, the secondary
` The combination of these two reference is
`reference, namely, Thominet, who disclosed known
`being described in my declaration with the two
`technique of using multiple directional beam
`0
`aspects of execution software and the hardware.
`regions. That's what I meant, additional
`11
`alternative, is there is a region, meaning, almost
` Q Okay. So in paragraph 135, when it
`12
`like grouping.
`starts off and says, Additionally or alternatively,
`13
`a POSA would have sought to incorporate known
` Q So is "additional" the same as
`14
`components (hardware implementation), is the
`"alternative"?
`15
`"additionally or alternatively" language referring
` MR. FITZSIMMONS: Objection, form.
`16
`to the software implementation that preceded or not?
` Q In that sentence in paragraph 126, is
`17
` A Again, I'm not a lawyer to give you
`"additional" the same as "alternative"?
`18
`precise description for the legal basis of
` MR. FITZSIMMONS: Objection, form.
`19
`obviousness.
` A My statement in my declaration, I stated
`20
` But my understanding is when you combine
`additional, alternative, and that disclosed by
`21
`two prior arts, you can describe two -- the
`Thominet, that group the microbeams in the different
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`35
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`Transcript of Jianzhong Jiao, Ph.D.
`Conducted on October 3, 2023
`33
`motivation to combine two prior arts in the way that
`person of ordinary skill would look into this
`disclosure. In my declaration, I happen to group
`them into software and hardware.
` Is your question saying, is -- both is
`necessary or both is alternative, addition? All I
`said is my declaration, they're alternatively,
`additionally.
` Q I'm trying to understand what it means
`when you say "additionally or alternatively."
` What is -- the hardware implementation is
`in addition to what?
` A In the declaration, it means addition to
`paragraph 131 and the following paragraph. Then I
`stated also alternatively and additionally, you can
`combine the hardware. You can have hardware
`implementation starting from paragraph 135.
` Q Okay. So hardware implementation can
`then be added to the software implementation that's
`described in paragraphs 131 to 134?
` MR. FITZSIMMONS: Objection, form.
` A I will still use my statement in
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`reference, semiconductor light source 10 on the
`curved surface 12. And following that, and also
`says, combining into Beam's system (with a flat
`array).
` In my view, this is additionally,
`alternatively, software -- I mean, hardware
`addition.
` Q I'm sorry. It's not clear when you say
`"additional reference." What are you referring to?
` MR. FITZSIMMONS: Objection, form.
` Q In your prior answer, you said, Thominet
`was an additional reference, semiconductor light
`source 10 on a curved surface. I'm not clear what
`is -- again, I'm not clear what'