UNITED STATES
`INTERNATIONAL TRADE COMMISSION
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`
`.
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`
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`In the Matter of:
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`CERTAIN MOBILE DEVICES
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`AND RELATED SOFTWARE
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`
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`Investigation No.
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`337-TA~750
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`)
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`)
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`)
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`.
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`OPEN SESSION
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`Pages:
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`1 through 100 (with excerpts)
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`Place:
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`Washington, D.C.
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`Date:
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`September 23, 2011
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`HERITAGE REPORTING CORPORATION
`Ofiicial Reporters
`1220 L Street, N.W., Suite 600
`
`,
`
`I
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`. ,
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`Washington, D.C. 20005
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`(202) 628—4888
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`contracts@hrccourtreporters.com
`
`
`INTERNATIONAL TRADE COMMISSION
`
`
`
`.
`
`
`
`In the Matter of:
`
`CERTAIN MOBILE DEVICES
`
`AND RELATED SOFTWARE
`
`
`
`Investigation No.
`
`337-TA~750
`
`)
`
`)
`
`)
`
`.
`
`OPEN SESSION
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`Pages:
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`1 through 100 (with excerpts)
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`Place:
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`Washington, D.C.
`
`Date:
`
`September 23, 2011
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`HERITAGE REPORTING CORPORATION
`Ofiicial Reporters
`1220 L Street, N.W., Suite 600
`
`,
`
`I
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`. ,
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`Washington, D.C. 20005
`
`(202) 628—4888
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`contracts@hrccourtreporters.com
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`
`
`BEFORE THE
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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`
`
`In the Matter of:
`
`CERTAIN MOBILE DEVICES
`
`AND RELATED SOFTWARE
`
`
`
`Investigation No.
`
`337~TA~750
`
`)
`
`)
`
`)
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`Hearing Room A
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`United States
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`International Trade Commission
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`500 E Street, Southwest
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`Washington, D.C.
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`Friday, September 23, 2011
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`PREHEARING AND TUTORIAL
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`The parties met, pursuant to the notice of the
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`Judge,
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`at 9:00 a.m.
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`BEFORE:
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`THE HONORABLE THEODORE R. ESSEX
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`Heritage Reporting Corporation
`(202) 628—4888
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`APPEARANCES:
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`For Complainant Apple:
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`MARK G. DAVIS, ESQ.
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`BRIAN E. FERGUSON, ESQ.
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`ROBERT T. VLASIS, ESQ.
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`EDWARD S.
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`JOU, ESQ.
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`CHRISTOPHER T. MARANDO, ESQ.
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`Weil, Gotshal & Manges LLP
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`1300 Eye Street, N W., Suite 900
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`Washington, D.C. 20005
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`JILL J. HO, ESQ.
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`BRIAN C. CHANG, ESQ.
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`Weil, Gotshal & Manges LLP
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`201 Redwood Shores Parkway
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`Redwood Shores, CA 94065
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`MATTHEW D. POWERS, ESQ.
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`STEVEN S. CHERENSKY, ESQ.
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`PAUL T. EHRLICH, ESQ.
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`ROBERT L. GERRITY, ESQ.
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`Tensegrity Law Group LLP
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`201 Redwood Shore Parkway
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`Redwood Shores, CA 94065
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`Heritage Reporting Corporation
`(202) 628—4888
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`APPEARANCES (Continued):
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`For Respondent Motorola Mobility, Inc.:
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`CHARLES K. VERHOEVEN, ESQ.
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`DAVID EISEMAN, ESQ.
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`Quinn Emanuel Urquhart & Sullivan LLP
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`50 California Street, 22nd Floor
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`San Francisco, CA 94111
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`EDWARD J. DeFRANCO, ESQ.
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`Quinn Emanuel Urquhart & Sullivan LLP
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`51 Madison Avenue, 22nd FLoor
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`New York, New York 10010
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`DAVID A. NELSON, ESQ.
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`Quinn Emanuel Urquhart & Sullivan LLP
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`500 West Madison Street, Suite 2450
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`Chicago, Illinois 60661
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`APPEARANCES (Cont’d):
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`For ITC Staff:
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`LISA KATTAN, ESQ.
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`ANNE GOALWIN, ESQ.
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`U.S. International Trade Commission
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`500 E Street, S.W.
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`Washington, D.C. 20436
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`Attorney—Advisor:
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`GREGORY MOLDAFSKY, ESQ.
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`Attorney—Advisor
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`Office of Administrative Law Judges
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`U.S. International Trade Commission
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`500 E Street, S.W.
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`Washington, D.C. 20436
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`*** Index appears at end of transcript ***
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`P R O C E E D I N G S
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`(9:00 a.m.)
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`JUDGE ESSEX: All right. This is a
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`preliminary hearing in Certain Mobile Devices,
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`Related Software, case 337—TA—750.
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`Complainant, would you like to
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`introduce yourself for the record.
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`MR. POWERS:
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`Thank you, Your Honor,
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`Matt Powers for Apple.
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`MR. DAVIS: Mark Davis, Weil Gotshal,
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`for Apple.
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`MR. FERGUSON: Brian Ferguson, also
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`for Apple.
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`MR. EHRLICH:
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`Paul Ehrlich for Apple.
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`MR.
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`JOU:
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`Ed Jou for Apple.
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`MR. GERRITY: Robert Gerrity for
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`Apple.
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`Mr. MELAUGH: David Melaugh for Apple.
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`MR. VLASIS: Robert Vlasis for Apple.
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`MS. HO:
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`Julie Ho for Apple.
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`MR. CHANG: Brian Chang for Apple.
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`MR. MARANDO: Chris Marando for Apple.
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`JUDGE ESSEX:
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`Thank you very much.
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`Respondent's counsel?
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`MR. VERHOEVEN: Good morning, Your
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`Honor, Charles Verhoeven representing Motorola
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`Mobility. With me is my partner, David Nelson,
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`and Ed DeFranco, David Eiseman. And we also
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`have in—house from Motorola, Tom Miller is
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`here, Your Honor.
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`JUDGE ESSEX:
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`Thank you very much.
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`Staff?
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`MS. KATTAN: Good morning, Your Honor,
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`Lisa Kattan from the Office of Unfair Import
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`Investigations. With me are Anne Goalwin and
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`intern Gary Coad.
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`JUDGE ESSEX: Welcome. Welcome. All
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`right. Before we get into the issues today,
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`let me go over some housekeeping matters.
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`We’re scheduled for September 26th through
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`October 5th. Our normal hours are going to run
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`from 9:00 o’clock to 5:00 o’clock. At the end
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`of each day, everyone will have 20 minutes to
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`clear the courtroom and lock up.
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`I would ask
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`you to please be prompt, because my Staff has
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`to stay, and if you linger,
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`they have to
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`linger.
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`Parties will be responsible for
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`allocating and keeping track of your own time.
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`The exhibits, as they are presented, will be
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`received in evidence at the end of the person’s
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`testimony,
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`including the cross, redirect, and
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`recross.
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`Talk among yourselves.
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`No one has to
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`read exhibits in in front of me. You can work
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`with the court reporter and get those in the
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`record.
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`Parties may use physical exhibits.
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`However, you are warned —— and I think Motorola
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`is aware of this from a recent previous case ——
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`that if you put in physical exhibits, you don’t
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`get those back.
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`If you want the exhibit back,
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`like
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`your engineers have a favorite old phone that
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`is their own invention, please take a picture
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`of it, put the picture in the record as a
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`substitute. You may do that without asking
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`permission, but if you leave the physical
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`exhibit in, it is mine.
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`We’re going to, with this case, as we
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`have been experimenting with,
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`try to eliminate
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`separate findings of facts. We’re going to ask
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`you to cite the findings of facts and such in
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`the briefs, and any citations and supporting
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`evidence should be directly to the exhibits or
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`the trial testimony.
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`In light of this, we’re going to try
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`page limits as follows:
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`For the initial
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`post—hearing briefs,
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`I have a ZOO—page page
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`limit.
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`To those of you who may have questions
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`about it and so on,
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`that is 200 pages, double
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`spaced, 12 point font, Microsoft standard.
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`If you write more, if you feel a
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`burning desire to do appendices, addendums,
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`footnotes, attachments, however you want to
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`characterize it, after 200 pages,
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`I lose the
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`ability to read.
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`You can do them.
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`I am not going to
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`read them. Your post—page reply briefs are
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`lOO—page limit.
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`If there is a real strong need
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`to do otherwise,
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`I will entertain motions,
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`if
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`it cannot possibly be done within 200 pages or
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`cannot possibly be done within 100. Make a
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`motion. Otherwise,
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`I will not read past those
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`limits.
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`I will add also that greater minds
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`than my own have found brevity is the soul of
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`wit.
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`Judge Michel has urged that less can be
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`more. And anything else that might encourage
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`conciseness,
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`I would ask you to cite.
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`Initial post—trial briefs and the
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`final exhibit lists, it is my calculations are
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`due October 19th, 2011. Reply briefs will be
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`due October 28th, 2011. At the end of the
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`hearing,
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`the parties will have two days for
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`courtroom cleanup.
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`Do you have any questions or comments
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`with those matters?
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`I would add briefly that I do allow
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`coffee and other beverages in the courtroom.
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`However,
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`I also would hasten to add you are
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`responsible to clean up your own areas and pick
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`up after yourselves. Nobody here is assigned
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`to do that at the Commission.
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`If it becomes a
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`problem,
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`then I will revisit that, but for
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`right now, beverages and things of that nature
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`are permitted, as long as we abide by that rule
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`that we’re going to clean up after ourselves.
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`Let me turn, if there is nothing else
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`administratively right now from any of the
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`parties, we will go into the motions in limine
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`and objections.
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`Hearing nothing, we had a number of
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`agreements on the motions in limine.
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`If I skip
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`something or I miss —— lose track of something
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`and that, at the end of the ones that I know
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`about, we will take up the ones I have
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`forgotten, if there are any.
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`We will start with motion in limine
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`number 6 to exclude the testimony of witnesses
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`who were not offered for deposition or in the
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`alternative to compel deposition. And Apple
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`has moved to preclude a number of witnesses.
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`I
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`am not going to go into detail about which ones
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`and so forth for the record.
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`Right now,
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`I do find that those
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`witnesses were timely disclosed and on a
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`procedural schedule that we have and the rules
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`that we have, Motorola is under no obligation
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`to disclose which one it actually intended to
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`call at hearing, until they filed a first
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`prehearing statement.
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`I find there was an
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`opportunity to interview the witnesses,
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`take
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`depositions, and so on, so none of those
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`motions regarding witnesses are granted.
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`They
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`are all denied.
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`I think Apple have ample opportunity
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`for cross—examination.
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`They will be able to
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`handle the witnesses.
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`Turning to Motorola and their motion
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`in limine to preclude Apple from introducing an
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`expert opinion testimony of an undisclosed
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`expert, and this apparently involves an expert
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`witness that has been disclosed,
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`Dr. Subramanian —— can you pronounce that?
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`MR. DAVIS: Dr. Subramanian.
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`JUDGE ESSEX: Dr. Subramanian.
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`I
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`probably should know that.
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`I believe I have
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`had him before.
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`In any event, it is quite common in
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`these cases that experts come in and do rely on
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`teardown reports, reports from other agencies,
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`people they hired to conduct tests and so
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`forth.
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`The motion is denied.
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`To the extent he may not have
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`supervised the lab,
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`that he may not have
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`supervised those to provide proper information,
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`those are all issues that would go to weight
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`and I am confident that the abilities of the
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`attorneys cross-examining will help me assess
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`the appropriate weight to give those reports
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`and give to the expert testimony.
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`So those are denied.
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`He may testify.
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`He may use the UBM reports. And any problems
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`with those,
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`I expect will be brought out in
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`cross—examination.
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`We will turn to Apple’s high-priority
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`objections that I’m aware of now, number 2,
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`that Motorola should be precluded from
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`submitting an expert report and incorporating
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`the expert report into expert witness
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`statements.
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`I find no problem with the manner of
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`the expert reports having been done by
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`incorporation.
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`Those matters can be brought
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`in.
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`They could be brought in
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`question—by—question. And I don't specifically
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`state how those things ought to be done in the
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`witness statements and so forth.
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`So to the extent that they incorporate
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`by reference or have references to expert
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`reports that are included in any fashion in a
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`witness statement,
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`the parties are aware of
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`those,
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`they can bring it out on
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`cross—examination.
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`The entire expert reports
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`are not evidence and that, but to the extent
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`they are alluded to in the witness statement
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`and covered,
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`then I, again, suggest
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`cross-examination can cover that matter, and I
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`deny their motion to preclude.
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`The reports themselves are not
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`evidence and will not be admitted, but
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`to the
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`extent they are included in a witness
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`statement,
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`that is permissible. You can
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`cross-examine on it. And we will just deal
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`with them on a case-by—case basis.
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`Regarding the number 6,
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`the objection
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`is the same as the motion in limine and that’s
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`covered by the ruling above.
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`It is denied.
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`Objection number 9, Motorola should be
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`precluded from offering testimony regarding
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`products that are not accused of infringing the
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`’607 patent and the ’828 patent.
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`I am puzzled.
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`If Motorola wants to
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`use their time to attack patents that are not
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`in issue here,
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`I don’t know why Apple -— it is
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`irrelevant and can be excluded on that grounds.
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`I’m not prepared to rule right now. We will do
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`it on a question~by—question basis, when those
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`witnesses come up.
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`But to the extent that one party
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`should use their time on matters that are not
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`before me,
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`I find odd that this is made as an
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`objection, but I will grant it,
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`to the extent
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`that if there are questions regarding patents
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`not in issue,
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`those would be ~— they would have
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`to demonstrate the relevance or they will be
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`excluded, but on a question—by—question basis,
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`we will take those up when those witnesses are
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`in front of us.
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`Number 10, Motorola should be
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`precluded from offering designated deposition
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`testimony outside the scope of the corporate
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`deposition. Again,
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`I would like you to work it
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`out.
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`To the extent a witness has offered
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`something that is not within their designation,
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`that would be irrelevant.
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`But we will have to take it up on a
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`question—by~question basis.
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`The objection will
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`be well—founded if the witness is speaking of
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`something that's clearly outside their area,
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`unless they are offered as a fact witness, and
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`it is within their personal knowledge. But I
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`would have to see what questions there are and
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`rule on them specifically, so I am going to
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`take that up again witness—by—witness or
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`question~by~question.
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`If you believe when a
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`witness statement is offered,
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`there is an offer
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`of evidence in there that’s beyond the scope,
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`we will take those up specifically.
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`Regarding Motorola’s high—priority
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`objection, saying Apple should be precluded
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`from offering opinion testimony of the
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`undisclosed expert, again,
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`this is the same as
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`the motion in limine and it is denied.
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`Regarding evidence offered without a
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`sponsoring witness,
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`I have never seen so many
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`proposed exhibits without a sponsoring witness.
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`To the extent that the parties are in agreement
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`and it makes sense,
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`I will allow it.
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`I find it unusual and we will see how
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`it goes and that, but if the parties do not
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`agree on it,
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`the evidence normally must have a
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`sponsoring witness, and I will so hold. But to
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`extent that the parties are in agreement,
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`that
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`will be fine.
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`I have reviewed the attached
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`stipulations,
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`they’re fine with the Court.
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`The
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`more that the parties can agree and streamline
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`the case, generally the happier you will find
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`me to be.
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`So I will accept the stipulations.
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`I was handed one more thing this
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`morning that we hadn’t covered up in my office,
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`and apparently there is a Respondent’s motion
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`to terminate the investigation with respect to
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`the ’430 patent, suggesting Apple does not own
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`the patent and has no standing asserted.
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`Is
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`that still a motion in front of us?
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`MR. EISEMAN:
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`It is, Your Honor.
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`JUDGE ESSEX: All right. And I assume
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`Apple is claiming they still own the patent?
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`MR. POWERS: Yes, Your Honor.
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`JUDGE ESSEX:
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`Then the facts are in
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`dispute.
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`The motion will be denied and we will
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`see what the facts bring, but I assumed there
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`would be a factual dispute on this. As you
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`know,
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`the rules —— I would have to interpret
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`the facts that are before me in the most
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`favorable manner for Apple, and at this time,
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`as long as there is disagreement, we’re going
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`to hear the evidence on it so the motion is
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`denied at this time.
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`Those are the rulings I have. And the
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`issues I’m aware of as alive. There has been a
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`lot of progress and there has been a lot of
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`discussion of the parties, which I utterly
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`approve.
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`So what was originally in front of me
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`was fairly massive and this has been whittled
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`down. Have I missed any motions in limine or
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`priority objections that are still in front of
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`us before we go? Complainant?
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`MR. POWERS:
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`I believe not, Your
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`Honor.
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`MR. VERHOEVEN: No, Your Honor.
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`JUDGE ESSEX: Staff?
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`MS. KATTAN: No, Your Honor.
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`JUDGE ESSEX: All right. Complainant,
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`do you have —— how would you like to proceed
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`this morning?
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`I understand that you have
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`either some argument or questions?
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`MR. POWERS: We’re prepared to proceed
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`with the technical tutorial, Your Honor, with
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`our expert witness.
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`JUDGE ESSEX: All right.
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`Is there
`
`anything else to take up before we go to
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`tutorials?
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`MR. VERHOEVEN: Nothing else, Your
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`Honor.
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`MR. DAVIS: Your Honor,
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`just a couple
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`follow-up issues with regard to Your Honor’s
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`ruling. With regard to the ability to cross
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`the witnesses for which no depositions were
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`taken, we have asked Motorola for their trial
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`testimony in the recent
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`’744 case, Your Honor,
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`to help us with that cross. And they haven’t
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`denied that they have a duty to supplement or
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`that it is subject to discovery requests in
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`other cases for which there is a cross-use
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`agreement,
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`they have just been dragging their
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`heels in providing us that transcript.
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`So, Your Honor, we would just ask that
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`Motorola have us ~— provide us with those
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`transcripts so we can use those in
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`cross—examining these witnesses for which we
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`weren’t able to take a deposition.
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`JUDGE ESSEX: All right. Let me just
`
`say one thing at the outset.
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`If you want to
`
`stay on my good side, and I don’t recall having
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`discussed with you beforehand, but I would ask
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`you, please do not characterize things in a
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`negative fashion,
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`the dragging heels.
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`I
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`understand what you want and what you need, but
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`characterizing it that way really doesn’t help,
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`and I find parties cooperate better if we do
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`not use derogatory terms to describe the
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`actions.
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`What you are saying is you have not
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`yet received it. Perfectly fine. But as
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`people have appeared before me, attorneys
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`appeared before me realize,
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`I want to keep
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`those types of characterizations out of the
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`cases and that. As far as I know, everyone
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`here has behaved as a thoroughly competent
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`professional, and I want to keep our
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`conversations on that basis.
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`MR. DAVIS: Very good, Your Honor,
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`I
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`apologize.
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`JUDGE ESSEX:
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`If you would. Motorola,
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`do you have that testimony?
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`Do you want to
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`provide it? Where are we on it?
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`MR. DeFRANCO: Your Honor, we did
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`attempt to cooperate. We provided the
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`testimony of some witnesses that we thought was
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`relevant,
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`the PenPoint prior art reference, you
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`may remember from the other case,
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`the same
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`three witnesses are scheduled to appear here.
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`We gave them that testimony because it
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`was on the same prior art. We
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`thought that was
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`a reasonable place to draw the line because, as
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`you are aware, and we informed them, one of the
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`experts is in common between the two cases,
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`Dr. Locke, but he wasn’t crossed in the other
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`case. His direct involved different patents.
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`And there was confidential information
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`in that testimony. We’re all in trial mode.
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`We thought, you know,
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`that was the appropriate
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`place to draw the line. There didn’t seem to
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`be the pressing need for us to figure out what
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`was confidential or not
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`in Dr. Locke’s direct
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`examination, given that it involved different
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`patents and different technologies. There are
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`a couple of fact witnesses that would apply to
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`as well. There was the same issue there, Your
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`Honor, with respect to confidential information
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`and we didn’t see the overlap warranted the
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`discovery.
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`Our last point, which we expressed to
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`them, obviously, discovery has long since
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`closed. We said this would be a two-way
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`street. Their witnesses have testified at all
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`sorts of hearings and trials. Are we going to
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`get all that information?
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`It seemed
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`unwarranted to let them open the door in that
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`respect. We thought, as I said, we drew the
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`line at a reasonable place and that was our
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`position overall on it.
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`JUDGE ESSEX: All right. Staff, would
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`you like to be heard regarding this matter?
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`MS. KATTAN: No, Your Honor.
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`JUDGE ESSEX:
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`Thank you. And I do
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`note discovery has closed a long time ago.
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`I
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`appreciate cooperation.
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`I like to see it.
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`To
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`the extent that these appear to be discovery
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`requests,
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`then I am not going to entertain
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`them.
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`I appreciate that there is a long
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`witness list, but you did have it within the
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`discovery period.
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`I know it is a burden to depose
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`everyone.
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`I understand that it can cause
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`burdensome costs, but we are where we’re at and
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`we’re going to proceed.
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`I am not going to
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`issue any kind of order regarding any further
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`testimony.
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`To the extent parties can cooperate
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`and if you have information they are interested
`
`in, perhaps a deal can be done, but there will
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`be no further orders regarding discovery at
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`this time.
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`Let’s proceed with the tutorial.
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`Counsel?
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`MR. FERGUSON:
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`Thank you, Your Honor,
`
`good morning.
`
`I am just here to present our
`
`expert, who will actually be doing the heavy
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`lifting today,
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`in presenting the technology
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`tutorial. His name is Dr. Ravin Balakrishnan.
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`Dr. Balakrishnan is a professor at the
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`University of Toronto.
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`He has a Ph.D.
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`in
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`computer science. His research interests
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`involve the technology we think is very germane
`
`to the case today and includes touch input and
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`sensing technologies.
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`He has published over 100 papers in
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`that area.
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`He is an inventor on nine U.S.
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`patents. And we’re very pleased to present him
`
`here today.
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`He will, of course, be doing some
`
`additional heavy lifting when it comes to the
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`trial starting on Monday.
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`And unless there are any questions,
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`I
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`will just turn the floor over to him.
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`I
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`believe we have handed out copies of our
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`tutorial to everyone.
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`JUDGE ESSEX: Well,
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`I have got my
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`copy. Does everybody else have one?
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`MR. VERHOEVEN: Yes, Your Honor.
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`JUDGE ESSEX: All right. Doctor.
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`DR. BALAKRISHNAN:
`
`Is the microphone
`
`good? All right.
`
`So I guess that's my bio sheet, which
`
`Brian has already introduced me.
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`So the
`
`overview of today’s tutorial is we’re going to
`
`be talking about several different topics.
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`First of all, we’re going to be talking about
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`multi—touch touch—screen operation. And within
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`that,
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`I will be talking about the hardware and
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`the software relevant to that technology.
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`Subsequent to that,
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`I will be talking
`
`about adding components to a computer system,
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`which is the second topic. And then we will
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`round this off with talking about
`
`the specific
`
`technologies related to the three patents that
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`are of interest in this case,
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`the first one
`
`being the multi—point touchscreens patent,
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`the
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`’607 patent,
`
`followed by the ellipse fitting
`
`for multi-touch surfaces patent, which is the
`
`’828 patent; and ending with the
`
`object—oriented system locator system patent,
`
`the '430 patent.
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`So first let’s start with multi—touch
`
`touchscreen operation. And just at a very high
`
`level,
`
`I have on the left—hand side of the
`
`screen a hypothetical phone and the user
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`bringing a finger down to touch it. And when
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`the user touches it,
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`the touch device requires
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`two broad pieces of technology to process that
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`touch.
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`First, it needs some hardware to sense
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`that the user has touched it at a particular
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`location. And then some software to actually
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`identify and process that touch data into a
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`user command or gesture that can be applied to
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`a particular software application.
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`So in terms of the hardware,
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`there are
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`several different types of sensor technologies
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`that can sense that user touch on the device.
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`And here are some examples. There are
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`resistive technologies,
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`infrared, optical ones
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`using cameras, surface acoustic wave
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`technologies, and the last example here are the
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`capacitive technology is the one I want to
`
`focus on because it is the most germane to the
`
`patent of interest here in this case.
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`So let’s talk about capacitive
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`sensors.
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`So capacitive sensors, and I am going
`
`to talk about four broad topics within that
`
`genre of sensing. First of all,
`
`there is an
`
`issue of what is known as surface capacitance.
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`Then I will talk about entire row and entire
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`column capacitance sensing,
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`followed by
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`row/column intersection capacitance sensing,
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`and then I will discuss two terms that are of
`
`interest, which are mutual versus
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`self—capacitance.
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`So let’s take each of these in turn
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`now.
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`So, first of all, before I get into those
`
`four sub—topics, what is capacitive sensing at
`
`a very high level?
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`So when two conductive,
`
`electrically conductive elements come together,
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`the electrical charge between them changes.
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`And this change in energy between
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`those two elements is measured as what is known
`
`as capacitance. And what is also interesting
`
`is that the human finger is electrically
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`conductive. And if you bring your finger
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`towards an electrically charged element,
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`the
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`capacitance change caused by that finger can be
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`used to detect touching.
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`So that's a very high overview of what
`
`capacitive sensing is all about.
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`So let’s talk
`
`about surface capacitance now.
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`So what I’m showing you on this
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`screen, which is CDX~10.0lO,
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`is a schematic.
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`And on the top is a side View of a hypothetical
`
`touchscreen device.
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`On the bottom is a frontal
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`view of it.
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`And, first of all,
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`this device is
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`going to have a conductive coating,
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`some kind
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`of conductive coating applied to an insulator.
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`All right?
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`Now, current will be applied to the
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`four corners of that conductive coating. And
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`when a finger comes towards the surface and
`
`then touches it, a capacitor is formed between
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`that finger and that conductive coating. And
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`essentially draws current from those corners.
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`And you see there in the red circle,
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`the point of contact representing that finger.
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`And that location of that finger can be
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`calculated by measuring the change in current
`
`at those four corners.
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`So based on that, we can interpolate
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`the X and Y position of that finger or point of
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`contact.
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`Now,
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`that was a single finger touching
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`that conductive surface capacitor.
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`Now, what
`
`happens if two touches happen to touch that
`
`same device? And here the two touches are
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`indicated in the red circles.
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`With this technology, what happens is
`
`only the average position is reported.
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`So the
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`average of those two touches roughly is
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`indicated by the orange circle. And, as a
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`result, you get a value that is indicative of
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`the approximate center of those two touches and
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`not the two touches separately, which might be
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`more desirable in some situations.
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`So surface capacitance touch screens,
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`which detect single touches quite reliably are
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`used in devices where such single touch
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`applications make sense,
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`for example,
`
`in ATM
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`machines that many of us are familiar with.
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`And this is an example of an ATM—type terminal.
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`Now, moving along from surface
`
`capacitance,
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`if we want to do a bit more than
`
`just sense a single touch accurately, we can
`
`look at what’s known as entire row and entire
`
`column capacitive sensing.
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`And what we do here is on this graph
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`~- sorry, on this slide,
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`I’m going to show a
`
`hypothetical touch sensor being built up with
`
`rows, several rows of conductive material.
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`instead of a single piece like in the previous
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`surface capacitance technology, here we’re
`
`going to break it up into rows and each row has
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`a lead coming out of it that will take a charge
`
`on it, electrical current on it.
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`And we overlay this with an insulating
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`layer. And then overlay it with a series of
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`columns of similar conductive material running
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`orthogonal or perpendicular to the rows that
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`were previously laid down.
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`So you have
`
`basically got a grid of rows and columns of
`
`conductive material separated by an insulating
`
`layer.
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`And the way this technology works is
`you run currents through these conductors and
`
`measure the capacitance relative to ground.
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`And any time you touch a portion of this
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`sensor, one or more rows and columns will be
`
`activated.
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`So in this example,
`
`I have shown one
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`row and one column with the hypothetical values
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`of capacitance being read. Now,
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`if you have
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`two touches on the same row,
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`that activates the
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`same row, it will activate one row but
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`two
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`columns, for example.
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`Now,
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`if I have two touches on
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`different rows and different columns, you get
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`two rows and two columns being activated. As
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`you can see here,
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`the two fingers are touching
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`two different spots.
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`Now, an interesting thing happens with
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`this technology,
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`is if I take my two fingers
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`and I touch a very different two positions but
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`which happen to activate the exact same rows
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`and columns,
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`the sensor gives me the same set
`
`of values.
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`80 I am going to go back and forth
`
`here.
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`Two fingers in this orientation activate
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`those two columns and those two rows
`
`(indicating),
`
`the same values.
`
`Now,
`
`if I move
`
`my fingers to another orientation, which
`
`happens to activate those same rows and
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`columns,
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`I get those same values, and, as a
`
`result of putting these two side—by—side, it is
`
`impossible to distinguish between these two
`
`very different touches using this technology.
`
`So another problem with this
`
`technology is if I have a very large touch or a
`
`larger touch, so, for example,
`
`I put a thumb
`
`down with much of it touching the surface, it
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`may activate three columns, for example, and
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`two rows.
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`And then if I subsequently put a
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`finger down with a smaller touch,
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`that would
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`typically only activate, say, one column and
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`one row.
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`In this case,
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`though, because the
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`thumb has already activated three of those
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`rows, it masks the smaller touch of the single
`
`finger.
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`As a result, it is difficult to say
`
`exactly where the finger is in terms of which
`
`row it is on.
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`So these are two potential problems
`
`with this entire row and entire column type of
`
`capacitive sensing.
`
`So let’s move on to the next type of
`
`capacitive sensing, which is known as row and
`
`column intersection capacitive sensing.
`
`So here we have a very similar kind of
`
`layout.
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`A series of rows of conductive
`
`material,
`
`like in the previous section, and we
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`call this drive rows in this case. And then
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`again we put an overlay insulating layer of
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`glass or plastic.
`
`And then overlay a series of
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`orthogonal or perpendicular columns of
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`conductive material. And these are the sense
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`columns.
`
`So this graph —— this figure looks
`
`very similar to the previous figure, except the
`
`way the sensing works is it is going to sense
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`10
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`11
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`12
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`13
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`14
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`15
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`16
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`17
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`18
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`19
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`2O
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`21
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`22
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`23
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`24
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`25
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`Heritage Reporting Corporation
`(202) 628—4888
`
`
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`31
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`the relative capacitance between the
`
`intersections of the rows and the columns as
`
`opposed to the rows and columns to its ground
`
`as in the previous case.
`
`And this type of sensor allows you to
`
`detect the changes of capacitance at the
`
`intersection.
`
`So when I put a finger down, it
`
`no longer activates the entire row and entire
`
`column. You get the points around the finger,
`
`around the intersection point.
`
`And if I put two fingers down like in
`
`the following figure (indicating), it activates
`
`the releva
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