`
`Transcript of Jianzhong Jiao, Ph.D.
`
`Date: August 2, 2023
`Case: Volkswagen Group of America, Inc. -v- Spero (PTAB)
`
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
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`SPERO EX. 2007
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` __________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________________________
` VOLKSWAGEN GROUP OF AMERICA, INC.,
` Petitioner,
` v.
` YECHEZKAL EVAN SPERO,
` Patent Owner.
` __________________________
` IPR2022-01586
` U.S. Patent No. 11,208,029 B2
` __________________________
`
` DEPOSITION OF JIANZHONG JIAO, PH.D.
` Washington, DC
` Wednesday, August,2, 2023
` 8:58 a.m. EDT
`
`Job No.: 501714
`Pages: 1 - 181
`Reported by: Judith E. Bellinger, RPR, CRR
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`2
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` Deposition of JIANZHONG JIAO, PH.D. held at
`the offices of:
`
` STERNE, KESSLER, GOLDSTEIN & FOX
` P.L.L.C.
` 1101 K Street NW
` Washington, DC 20005
` 202.371.2600
`
` Pursuant to notice, before Judith E.
`Bellinger, Registered Professional Reporter,
`Certified Realtime Reporter, and Notary Public in
`and for the District of Columbia.
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`3
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` A P P E A R A N C E S
`
`ON BEHALF OF THE PETITIONER:
` JASON A. FITZSIMMONS, ESQUIRE
` IAN SOULE, ESQUIRE
` STERNE, KESSLER, GOLDSTEIN & FOX,
` P.L.L.C.
` 1101 K Street, NW
` Washington, DC 20005
` 202.371.2600
`
`ON BEHALF OF VOLKSWAGEN GROUP OF AMERICA,
`INC.:
` ROBERT E. COLLETTI, ESQUIRE
` HAUG PARTNERS LLP
` 745 Fifth Avenue
` 10th Floor
` New York, NY 10151
` 212.588.0800
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`Conducted on August 2, 2023
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`4
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` A P P E A R A N C E S C O N T I N U E D
`
`ON BEHALF OF THE PATENT OWNER:
` ANDREW B. TURNER, ESQUIRE
` SANGEETA G. SHAH, ESQUIRE
` BROOKS KUSHMAN PC
` 1000 Town Center
` 22nd Floor
` Southfield, MI 48075
` 248.358.4400
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`5
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` C O N T E N T S
`EXAMINATION OF JIANZHONG JIAO, PH.D. PAGE
` By Mr. Turner 6
`
` E X H I B I T S
` (Attached to the transcript)
`Jiao Exhibits: PAGE
`Exhibit 1 Declaration 163
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`Conducted on August 2, 2023
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`6
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` P R O C E E D I N G S
` JIANZHONG JIAO, PH.D.,
` being first duly sworn, was examined
`and testified as follows:
` EXAMINATION BY COUNSEL FOR THE PATENT
` OWNER
`BY MR. TURNER:
` Q All right. Good morning, Dr. Jiao.
` A Good morning.
` Q Am I pronouncing your name correctly,
`Jiao?
` A Almost perfect.
` Q Excellent. Good.
` Do you understand you're here today for
`a deposition on IPR number 2022-01586?
` A Yes.
` Q Okay. Have you been deposed before?
` A Yes, I have.
` Q About how many times?
` A Approximately, 20ish.
` Q So you're a pro.
` Have you been deposed before for IPRs?
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`Conducted on August 2, 2023
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`7
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` A No.
` Q Okay. All right. So how did you
`prepare for your deposition today?
` A I first had a phone conversation with
`counsel here; that was last week. And I came to
`their office Monday, Tuesday, so we had reviewed
`my declaration. And that's pretty much the
`preparation for that time.
` Q Okay. And who did you meet with,
`anybody besides Ian?
` A And Jason.
` Q Okay. Anyone else outside of Sterne
`Kessler?
` A No.
` Q And what documents did you review in
`preparation for the deposition?
` A We reviewed my declaration and the arts
`referenced in my declaration, and the claims in
`the '029 patent.
` Q Okay. Did you review any documents
`that are not cited in your declaration?
` A Do you mean in preparation for my
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`8
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`deposition?
` Q Correct.
` A No.
` Q Who drafted your declaration?
` A We collaborated, like, drafted it
`together, meaning my counsel and myself.
` Q By your counsel, that's the gentlemen
`in this room?
` A Correct.
` Q Okay. And, approximately, how much
`time did you spend working on your declaration?
` A 40ish hours.
` Q Okay. And did you work with anyone,
`outside of the attorneys in this room, on
`preparing your declaration?
` A No.
` Q And what did you rely on in preparing
`your declaration?
` A I relied on the guidance from the
`counsels regarding the legal standards, as well as
`the arts that I reference in my declaration. And
`I also did my own search for the prior arts. We
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`9
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`had overall discussions regarding what arts should
`be referenced to the declaration.
` Q Do you know if any of the prior art
`references in your declaration were ones that you
`found?
` A At least a couple of them, yes.
` Q Do you know which references those
`were?
` A I think the reference that related to a
`conference PAL. It's a symposium piece. If I put
`it in the declaration. I'm pretty sure at least
`one, that was what I found.
` Q Did you attend the PAL conference?
` A I did twice, throughout all the series
`of PAL conference.
` Q So that's a recurring conference?
`Annual conference?
` A It's every other year until, I don't
`know, before pandemic situation changed.
` Q And what does "PAL" stand for?
` A Progress in Automotive Lighting. I
`think, since then, they changed to something else.
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`10
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`Back then, it was PAL, Progress in Automotive
`Lighting.
` Q All right. Have you worked with Sterne
`Kessler before this declaration?
` A No.
` Q Have you worked with Volkswagen prior
`to this declaration?
` A No.
` Q So even in your engineering experience,
`you never worked with Volkswagen.
` A Not directly. I may have a work
`relationship with their supplier, not directly
`with OEM.
` Q Okay. Where did you go to college?
` A I went to undergraduate school in
`Beijing, China, and so is my master program, in
`Beijing, China, which both are indicated in my CV.
` Q Okay.
` A Then I attended graduate school, first,
`at RPI, Rensselaer Polytechnic Institute, in Troy,
`New York. That was a physics degree program. I
`didn't finish it, but I transferred to
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`11
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`Northwestern University in Evanston, Illinois,
`that's where I finished my Ph.D. in electrical
`engineering.
` Q Okay. And when did you finish your
`Ph.D. program?
` A August 1989.
` Q Okay. And you said your program was in
`electrical engineering, correct?
` A Correct.
` Q Your Ph.D. program is.
` All right. So after school, where did
`you work?
` A Right after my Ph.D. program finished,
`I joined General Motors. At that time, their
`lighting division called Inland Fisher Guide
`division, IFG, that's GM internal lighting
`division. I worked there four years.
` Then I joined another lighting company
`called North America Lighting, which is subsidiary
`of Koito, which is a Japanese automotive lighting
`company. I worked there for 14 years.
` Q Okay. So what was the time frame that
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`12
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`you worked at GM, what years was it?
` A '89 to '93.
` Q Okay. When did you work at NAL?
` A '93 to 2007.
` Q Okay. What is NAL's business, or what
`was their business at the time you were working
`there? Did they provide products, services?
` MR. FITZSIMMONS: Objection. Form.
` A NAL is one of the automotive lighting
`companies in United States. Its customer,
`primarily, is OEM, and their product is a hundred
`percent exterior lighting, automotive lighting.
` Q What type of lighting does exterior
`lighting include?
` A Exterior lighting includes, loosely,
`two groups of lighting, forward lighting or
`road-illumination devices, and signal lighting,
`including signal and marking devices. All these
`is, clearly, we usually find everything mounted
`exteriorly of the vehicle body is considered
`exterior lighting.
` Q Does that include any rearward
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`13
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`lighting, like brake lighting?
` A It does.
` Q Okay. Is that considered -- that would
`be considered signal lighting?
` A Correct.
` Q Okay. So you mentioned NAL works for,
`primarily, Japanese OEMs; is that correct?
` Sorry. NAL primarily supplies products
`to Japanese OEMs?
` A If I recall the overall scope, I think
`it's about half and half, or maybe more domestic
`customers than Japanese customers.
` Q So you were at NAL for quite a long
`time.
` What were your different positions at
`NAL?
` A I was always the same position, just
`different title. I was in charge of the
`engineering and technology of the company.
` Q So that's a general manager position?
` A I was promoted to general manager. I
`was initially started as the manager.
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`14
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` Q So how many engineers did you have
`reporting to you at NAL?
` A Starting from day one, I was by myself.
` Q Okay.
` A The time I left, it was about 40ish.
` Q Okay. How did you have the engineers
`organized into teams?
` A I organized my department based on
`functionality. We have four grouping of
`functionality.
` Do I need to name all?
` Q Yes, please.
` A First is optical design group; the
`second is electronic technology group; the third
`one is engineering analysis and testing group; the
`first [sic] one is standard regulation group.
` Q So how did the different groups work
`together?
` MR. FITZSIMMONS: Objection to form.
` A It was pretty cohesive, collaborative
`work team.
` Q So how did you develop design criteria
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`15
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`for the different products?
` MR. FITZSIMMONS: Objection. Form.
` A Usually, it's based on the technology
`readiness, as well as customer, namely, OEM's
`specifications. Often, because I was in charge,
`R&D, we'd also tried to promote new technologies
`to the OEMs.
` Q So what were some of the new
`technologies that you promoted?
` A Different new light sources, including
`HID, high intensity discharge. Neon, gas
`discharge, LED, and lasers, as well as new
`configurations, optical configurations, electronic
`configurations, and sometimes we'll even promote
`new testing technologies.
` Q Okay. Do you remember when you first
`promoted LED technologies for forward-lighting
`applications?
` A Yes.
` Q When was that date?
` A It was in late '90s.
` Q Late '90s.
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`16
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` For this proposed LED forward-lighting
`design, did you propose replacing certain
`components with the LEDs?
` MR. FITZSIMMONS: Objection. Form.
` A I don't quite understand the question.
` Q Okay. Can you explain your proposed
`LED lighting designs to the OEMs in the '90s?
` MR. FITZSIMMONS: Objection. Form.
` A The concept is using LED as light
`source because the differences between LED and
`other traditional light sources, there's always
`related configuration and needed optically,
`electronically.
` Q So did you propose this as a
`replacement to existing LED -- sorry, strike that.
` Did you propose an LED lighting design
`as a replacement to a conventional headlamp?
` MR. FITZSIMMONS: Objection. Form.
` A Well, the headlamp always exist.
`Whatever the sources configuration used, anything
`new is replacement for existing. But there's
`always new configurations.
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`17
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` Q Okay. So in your proposed design, what
`components were you replacing?
` A In LED lighting category, especially in
`United States, we understand the regulation law,
`we call integrate beam; it means that LEDs cannot
`be separate from headlamp as replaceable, any
`bulbs. For that reason, any proposal for using
`LEDs, at that time, even up to today, will be
`complete integration, the whole headlamp
`replacement.
` Q So you said the LED cannot be separate
`from the headlamp for replacement.
` Does that mean you can't replace the
`individual component; it's a whole headlight,
`itself, needs to be replaced?
` A In the United States, that's law.
` Q Why is that?
` A Why did Congress wrote law like this?
` Q Correct?
` A Per my interpretation?
` Q Yes.
` MR. FITZSIMMONS: Objection. Calls for
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`18
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`a legal conclusion. Calls for speculation.
` THE WITNESS: I should answer, right?
` A Headlamp is very highly regulated
`lighting device, in terms it's performance,
`including the testing for the purpose of safety.
` For that reason, the headlamp light
`sources used to achieve these performances also
`regulated. For instance, if it's replaceable, the
`source has to be regulated and regulations demand
`what kind of source can be replaced with all the
`characteristics and the performance measures that
`government or regulation body believes.
` So an LED -- due to flexibility of
`mountable sources were not easy to establish.
`There hasn't been established replaceable source
`criteria by industry nor government. For that
`reason, today, regulation doesn't allow you to
`replace LED sources.
` Q Do you know what body creates these
`regulations?
` A Yes. DOT, NHTSA. National Highway
`Transportation Safety Agency. N-H-T-S-A, NHTSA.
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`19
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` Q Do you know if NHTSA has revised these
`regulations for forward-lighting since the time
`frame we're talking about?
` MR. FITZSIMMONS: Objection to form.
` A From time to time, there's some
`revisions. Usually, we also refer to
`interpretations to see what elements of the law
`could be interpreted. They do that anyways.
` Q Do you know what specific NHTSA
`provision regulates the light source for the
`headlamps?
` A I think it's part of 641. I can't
`recall. Different part from the M -- Motor
`Vehicle Safety Standard, MVSS108. The source is a
`different part.
` Q Can you describe some of the
`differences between a -- your proposed LED
`headlamp assembly and the existing conventional
`headlamp assemblies at the time you were at NAL?
` MR. FITZSIMMONS: Objection. Form.
` A Conceptually, is to use LED as light
`source.
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`20
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` Q So the -- what's included in the light
`source of the LED?
` A In general, we, as industry, we define
`light source, including emitting devices and
`controlled devices, and combine them by light
`source.
` Q What is the control device for these
`emitting devices?
` A Including -- they're often including
`drivers, ECUs, and -- or other features that have
`been integrated into ECUs that operate a light
`source.
` Q Are these ECUs and drivers integrated
`into the headlamp assembly or are they separate
`from the headlamp assembly?
` A Either. They can be either.
` Q Would you have one driver and
`controller in each headlamp assembly or would one
`of them control both headlamp assemblies?
` A In most of the cases, each lamp has
`dedicated driver, and they also can have an ECU
`that control both headlamps.
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`21
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` Q And this is -- your description of the
`LED driver -- your description of the LED headlamp
`assembly, this is with reference to the designs
`you proposed when you were at NAL, correct?
` A That was common practice at NAL
`anywhere.
` Q At the time, even when you were working
`there, correct?
` A Yes. As long as we introduce LED, we
`all understand the control that's needed.
` Q So where does the controls for the LED
`assembly receive its power on a vehicle
`application?
` A Battery.
` Q So, DC power?
` A Always.
` Q Okay. And what type of control signal
`does the controller provide to the LEDs?
` A It depends. If the function is only
`provided, the illumination purpose, then usually
`it's the power control, except the LED has its
`current device, there's also possibility of
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`22
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`testing variations.
` But if the function also changes
`through driving, and you do need other sensors to
`provide signal to allow the lamp to be operated
`and cut into the sensing signals.
` Q So these sensors, what are these
`sensors monitoring?
` MR. FITZSIMMONS: Objection. Form.
` A Because they have to have a sensor to
`monitor. Generally speaking, we break into three
`cases; A, road conditions; B, driving conditions;
`C, weather conditions. All the sensoring system,
`in general, they sense all these things
`surrounding the vehicles.
` Q So what type of sensors did you propose
`in the LED headlamp assemblies while you were at
`NAL?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A At the time we practiced the LEDs, the
`sensoring existing technology, we used a vendor to
`design our own sensor.
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`23
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` Q What type of sensors? What did these
`sensors measure? Lights? Did they measure
`temperature? What characteristics did they
`measure?
` MR. FITZSIMMONS: Objection. Form.
`Compound questions.
` A Again, the sensors, we have multiple
`types, remember, I mentioned the three categories.
`So, it depends more the sensing needs. You can
`have the sensoring for any type of signal, whether
`it's mechanical, electrical, or optical.
` Q So, how did you determine what type of
`sensors to include in your design?
` A Usually, it comes from OEM direction,
`if they ask, the beam should be changed according
`to whatever condition that associated sensor will
`be proposed.
` Q Can you give an example of a sensor
`proposed to meet certain beam change?
` A For example, if you want to make the
`beam swivel to the direction of turn or curve.
` There's a possibility you need a sensor
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`24
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`to sense, you know, steering wheel change, and you
`may, also, need to have a sensor to detect a road
`change. And if you want to look at how the light
`related to speed, you may need a speed sensor to
`tell where the light changes.
` Q Did the OEMs require sensors for
`performance of certain functionality, or was it
`more of a reliability concerns?
` MR. FITZSIMMONS: Objection. Form.
` A Almost in all cases, it's for
`performance.
` Q I'm sorry, did you say no cases or all
`cases?
` A All cases. Again, it is highly
`regulated, safety-wise.
` Q So you mentioned having a sensor to
`detect how the road changed. What type of sensor
`would that be?
` A The -- I cannot pinpoint specific
`sensing capability. Again, we're using vendors.
`If we want to have an ability to detect a road
`condition change, we know there's existing
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`25
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`technology, an already existing sensor can be used
`to detect road, whether it's optically or
`electronically. Or if you have ability to take
`other information, such as GPS or map data, that
`is all part of the control mechanism.
` Q You mentioned the sensor to detect
`optically or electrically, the road. Can you
`explain what you mean by the difference between
`those?
` A Optically, you can use camera as
`function, as a sensor. Electrically, you can use
`whatever pulsing signal to detect the road
`conditions. Again, I'm not really pinpointing
`specific sensor that we'd propose. We know these
`are existing technologies.
` Q So those were existing technologies at
`the time you were at NAL?
` A Yes.
` Q Would electronically -- sorry, strike
`that.
` Is a light sensor an electrical sensor
`for detecting road conditions?
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`26
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` A I don't understand that question.
` Q Can you give an example of an
`electrical signal -- sorry, electrical sensor for
`detecting road conditions?
` MR. FITZSIMMONS: Objection. Form.
` A We had to consider radar sensor, that's
`electrical.
` Q Reader?
` A Radar.
` Q Radar. Okay. Thank you.
` Did any OEMs include your proposed LED
`headlamp assembly in a commercial product while
`you were at NAL?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope. Relevance.
` A Remember, I left NAL 2007. So you're
`including entire time frame?
` Q I meant -- yes.
` A Oh, yes. We launched LED lamps with
`Koito, early 2000, for Lexus.
` Q Was that the first LED headlamp
`assembly in production, worldwide?
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` A That's what Koito claimed.
` Q I'm sorry, can you tell me that year
`again?
` A I don't recall the year, early 2000,
`but that's launch of production. The
`preproduction, prototype research is done years
`and years before, usually. The design phase for
`any automotive is three to four years.
` Q So, do you know when the first OEM
`started selling products, selling vehicles that
`had LEDs for forward-lighting applications?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope. Objection. Calls for
`speculation.
` A Early 2000s.
` Q And that was Lexus?
` A Yes, as I recall, Lexus.
` Q What functionality did this LED
`headlamp assembly for Lexus provide?
` MR. FITZSIMMONS: Objection. Form.
` A They provide -- I know it's primarily
`low beam. I don't recall it including high beam
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`28
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`or not. That's, again, that's production that's
`on the road. And prior to production, in the
`engineering model, we probably did study all kinds
`of possibilities long before production.
` Q So, the first production design that
`NAL provided that Lexus commercialized, the LEDs
`were only for the low beam?
` A NAL was just part of the family. It
`really was Koito Japan. That was low beam.
` Q Do you know if the controller for that
`headlamp assembly controlled both the high beams
`and the low beams?
` MR. FITZSIMMONS: Objection. Form.
` A I don't recall.
` Q Did this Lexus headlamp assembly
`include different optics for the high beam that
`used incandescent light bulb as compared to the
`optics for the low beam that used LED light
`source?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A LED, at least the LED portions use very
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`29
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`unique optics. I don't recall the high beam.
` Q Can you describe these optics for the
`LEDs?
` MR. FITZSIMMONS: Objection. Form.
` A If I recall, the very first production
`model, the old optics were used. If I recall, it
`was called the projection system, which used
`projectors. But they definitely used reflectors,
`but mainly it's using projector to project the
`beam.
` Q How is it different from the optics for
`the high beam that uses incandescent light bulbs?
` A Again, I don't recall the function of
`the high beam for that particular product.
` Q Why did the optics have the
`projection -- sorry -- strike that.
` Why did the low beam portion of the
`lamp assembly, that included the LEDs, include
`projection optics?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A At the time, I think the team believed
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`30
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`that the most optimized approach, based on
`efficiency, the overall optical efficiency, and
`restriction for the beam pad inside -- beam cavity
`size, the lamp size.
` Q So packaging was a concern?
` A Always.
` Q Did you have certain design guidelines
`for packaging space for LED assemblies?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A The space is always coming from OEM,
`usually starting from design studio, and
`negotiated with the engineering team to provide
`the space that is sufficient to put any kind of
`configuration into that pocket of a lamp. A
`collaborative effort between OEM's design studios,
`OEM engineers and lighting -- supply engineers'
`cost.
` MS. SHAH: I'm sorry. I think the
`realtime feed may be stalled out. Oh, okay.
` Q Are the packaging constraints different
`for every vehicle application?
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` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A Usually.
` Q And what drives those constraints?
` A Design studio.
` Q By "design studio," you mean the OEM
`design studio of the appearance of the vehicle?
` A Correct.
` Q Okay. Did the Lexus headlamp assembly
`include any sensors?
` MR. FITZSIMMONS: Objection. Form.
` Q For the --
` MR. TURNER: Sorry.
` Q Let me rephrase it.
` Did the Lexus headlamp assembly include
`any sensors that provided signals input to the LED
`control?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A I do not recall. I don't recall.
` Q Do you know why this design didn't have
`LEDs for the high beam functionality?
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` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A First of all, I do not recall. If I
`could speculate, it did not have high beam. But I
`do know, if the high beam was not included,
`primarily, it's due to the cost issue.
` Q You said cost issue?
` A Cost.
` Q Can you explain? What was the cost
`issue?
` A The automotive headlamp, regardless
`functions, there's always struggle between how
`much you want to put in cost-wise. Where low beam
`is always used, the high beam usage is very
`minimum, technically, it's less than 20 percent or
`even 10 percent usage. And the time putting LED
`source into a headlamp is very costly, where you
`have a lamp that is minimally used, usually, OEM
`didn't feel make economical sense.
` Q So it's difficult to justify the extra
`cost for high beam if you're only using it
`20 percent of the time?
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` MR. FITZSIMMONS: Objection. Form.
` A That's often OEM's preference.
` Q Okay. So what drove the cost increase
`for the LED light source?
` MR. FITZSIMMONS: Objection. Form.
`Objection. Scope.
` A LED, itself, the light source is a
`higher cost than traditional bulbs.
` Q When using LEDs, are there additional
`components that are needed in the assembly that
`are not needed in the conventional light source
`headlamp assembly?
` A It does. Does have additional
`components.
` Q What are some of these additional
`components?
` A Drivers, for instance, and PCPs that
`put an LED on board. These are components
`conventional light source do not need.
` Q Why does a conventional light source
`not need a driver?
` A Conventional light source is operated
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