throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`135
`
`---------------------------------X
`
`SAMSUNG ELECTRONICS CO., LTD., :
`
`SAMSUNG DISPLAY CO., LTD., :
`
`and SONY CORPORATION, :
`
` Petitioners, :
`
` v. : Case IPR2015-00887
`
` Patent 7,420,550 B2
`
`SURPASS TECH INNOVATION LLC, :
`
` Patent Owner. :
`
`---------------------------------X
`
` DEPOSITION OF TSU-JAE KING LIU
`
` VOLUME II
`
` Redwood Shores, California
`
` Friday, March 25, 2016
`
` 12:55 p.m.
`
`Job No.: 107362
`
`Pages 135 - 191
`
`Reported by: JENNY L. GRIFFIN, RMR, CSR, CRR, CLR
`
` LICENSE NO. 3969
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`

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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
`
` Deposition of TSU-JAE KING LIU, VOLUME II, held at:
`
`136
`
` Covington & Burling LLP
`
` 333 Twin Dolphin Drive, Suite 700
`
` Redwood Shores, California 94065
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` 650.632.4700
`
` Pursuant to notice, before Jenny L. Griffin, RMR,
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`CSR, CRR, CLR
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`

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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
`
`137
`
` A P P E A R A N C E S
`
` ON BEHALF OF PETITIONER SAMSUNG
`
` JAY I. ALEXANDER, ESQUIRE
`
` COVINGTON & BURLING LLP
`
` One CityCenter
`
` 850 Tenth Street, NW
`
` Washington, CD 2001-4956
`
` 202.662.5622
`
` jalexander@cov.com
`
` ON BEHALF OF PATENT OWNER, SURPASS TECH
`
` INNOVATION LLC:
`
` WAYNE HELGE, ESQUIRE
`
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
`
` 8300 Greensboro Drive, Suite 500
`
` McLean, Virginia 22102
`
` 571.765.7714
`
` whelge@dbjg.com
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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
`
`138
`
` I N D E X
`
` PAGE
`
` TESTIMONY OF:
`
` TSU-JAE KING LIU
`
` BY MR. HELGE .....................140
`
` - - -
`
` INDEX OF EXHIBITS
`
` (Attached to transcript)
`
` - - -
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` EXHIBITS DESCRIPTION PAGE
`
` Exhibit E Handwritten Diagram 141
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`

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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
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`Papers and Previously Marked Exhibits
`
`Referred to and not Attached to the Deposition:
`
`139
`
`EXHIBITS DESCRIPTION PAGE
`
`Samsung-1004 World Intellectual Property 141
`
` Organization Patent Application
`
` No. WO 02/075708 A2
`
`Samsung-1022 U.S. Patent 5,035.908 152
`
` Kozaki et al.
`
`Samsung-1023 U.S. Patent 6,384,892 B1 159
`
` Johnson et al.
`
`Samsung-1024 U.S. Patent 6,624,801 B2 161
`
` Moriyama
`
`Samsung-1020 Reply Declaration of Tsu-Jae 166
`
` King Liu, Ph.D.
`
`Samsung-1025 U.S. Patent 6,630,921 B2 167
`
` Janssen et al.
`
`Paper No. 22 Petitioners' Reply to Patent 171
`
` Owner's Response, US Patent
`
` 7,420,550
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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
`
`140
`
` P R O C E E D I N G S
`
` - - -
`
` TSU-JAE KING LIU,
`
`being first duly sworn or affirmed to testify to the
`
`truth, the whole truth, and nothing but the truth, was
`
`examined and testified as follows:
`
` - - -
`
` EXAMINATION
`
`BY MR. HELGE:
`
` Q. Good afternoon, Dr. Liu.
`
` A. Good afternoon, Mr. Helge.
`
` Q. Thank you for coming back out.
`
` I'm going to hand you a piece of paper here.
`
`It should be blank. Please take a look and confirm that
`
`it's blank.
`
` A. It is.
`
` Q. I see that you don't have a pen, so I'm going
`
`to hand you a pen. And can I ask you -- you probably
`
`remember this from Volume I. Can I ask you to please
`
`draw the symbol for a resistor on that paper.
`
` A. Okay. (Witness complies.)
`
` Q. And I'm going to ask you now, can you please
`
`draw a circle around that resistor.
`
` A. (Witness complies.)
`
` MR. HELGE: Can we please have the reporter
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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
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`141
`
`mark that drawing as Exhibit E.
`
` (Exhibit E is marked.)
`
`BY MR. HELGE:
`
` Q. Dr. Liu, I'm going to ask you to keep this
`
`piece, but I'm going to ask for my pen back, if you
`
`don't mind.
`
` A. Sure.
`
` Q. Thank you very much.
`
` Dr. Liu, we're going to look at a lot of
`
`documentation that you've already seen, I think. I'm
`
`going to hand you what's been marked as Exhibit 1004.
`
` And does that document look familiar to you?
`
` A. It does.
`
` Q. When was the last time you reviewed this
`
`document?
`
` A. This morning.
`
` Q. And I'd like to refer to this as Janssen '708,
`
`I think is the nomenclature consistent with how it's
`
`been used in this case so far.
`
` Is that acceptable for it to be referred to
`
`that way?
`
` A. Yes.
`
` Q. Okay. And, Dr. Liu, do you see -- in
`
`Exhibit 1004, do you see the symbol that you've drawn on
`
`Exhibit E appearing anywhere on that cover page of
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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
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`142
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`Janssen '708?
`
` A. I see a symbol that is similar on the cover
`
`pages of Janssen '708.
`
` Q. Okay. And you say -- Dr. Liu, you said just a
`
`moment ago you see a similar symbol; is that right?
`
` A. That's right.
`
` Q. Okay. And what makes the symbol you're
`
`referring to on Exhibit 1004, page 1, and the symbol on
`
`Exhibit E similar and not identical?
`
` A. They both show the symbol for a resistor, just
`
`the number of zigzags is different.
`
` Q. Okay. And does that have any practical
`
`difference from the standpoint of a -- accuracy of a
`
`resistor symbol, for example?
`
` MR. ALEXANDER: Objection. Form.
`
` THE WITNESS: Accuracy -- they both -- both
`
`symbols can be interpreted as resistive circuit
`
`elements.
`
`BY MR. HELGE:
`
` Q. Is there any quantitative value or any
`
`quantitative meaning to the number of zigzags in a
`
`resistor symbol?
`
` A. I don't think so.
`
` Q. Dr. Liu, I'm going to ask you to turn to
`
`page 13 of 18 in Exhibit 1004.
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`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
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`143
`
` And this is the diagram Figure 1 in
`
`Janssen '708; correct?
`
` A. That is correct.
`
` Q. And do you see the symbol from Exhibit E
`
`appearing in Figure 1 of Janssen '708?
`
` A. Again, it's a similar symbol. I do.
`
` Q. And is that referred to as Element 46? Is that
`
`correct?
`
` A. That's correct.
`
` Q. I'm going to ask you to please turn the page to
`
`14 of 18. This is Figure 2. And do you see that
`
`similar symbol also appearing in Figure 2 of
`
`Janssen '708?
`
` A. Yes, I do.
`
` Q. And is that Element 46?
`
` A. It is.
`
` Q. And on Figure 3 of Janssen '708, do you again
`
`see a similar symbol as you've drawn in Exhibit E?
`
` A. I do.
`
` Q. And is that Element 100?
`
` A. It is.
`
` Q. Let's turn the page, please, to 16 of 18. And
`
`do you again see similar symbols as those -- or as that
`
`you drew in Exhibit E appearing in Figure 4 of
`
`Janssen '708?
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`Deposition of Tsu-Jae King Liu, Volume 2
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` A. I do.
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` Q. And it looks like one element is labeled as
`
`144
`
`Element 100; correct?
`
` A. That's correct.
`
` Q. And the other element is unlabeled; correct?
`
` A. Correct.
`
` Q. Do you see any difference between the element
`
`labeled as 100 and the other element that is unlabeled
`
`in Figure 4 of Janssen '708?
`
` A. I do not.
`
` Q. And, finally, please turn to Figure 7. This is
`
`page 18 of 18. Once again, do you see a similar symbol
`
`to that which you've drawn on Exhibit E within Figure 7
`
`of Janssen '708?
`
` A. Yes, I do.
`
` Q. And is that element referred to as numeral 100?
`
` A. It is.
`
` Q. Okay. Are you aware of any other instances
`
`within Janssen '708 in which the identical or similar
`
`symbol to that which you've referred to in Exhibit E or
`
`that you've drawn in Exhibit E appears?
`
` A. I am not aware of any other instances.
`
` Q. And so we've identified those elements as
`
`numeral 46 and numeral 100 as we've gone through;
`
`correct?
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`Conducted on March 25, 2016
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`145
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` A. Correct.
`
` Q. Now, if I can ask you to please turn to page 5
`
`of 18 in Janssen '708. I'll direct you specifically to
`
`line 28. Do you see that line there?
`
` A. Yes, I do.
`
` Q. And do you see that Element 46 is described as
`
`a pixel?
`
` A. Yes, I do.
`
` Q. Are you aware of any other description provided
`
`in Janssen '708 for Element 46?
`
` A. I am not.
`
` Q. Can you please turn to page 7 of 18 within
`
`Janssen '708. And can you please direct your attention
`
`to line 17.
`
` Do you see that, Dr. Liu?
`
` A. Yes, I do.
`
` Q. And do you see there is a reference to pixel
`
`100? Is that correct?
`
` A. That's correct.
`
` Q. Are you aware of any other description for
`
`Element 100 within Janssen '708?
`
` A. No.
`
` Q. Dr. Liu, let's take a look at Figure 3 once
`
`again. This is on page 15 of 18. Do you see that?
`
` A. Yes, I do.
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`146
`
` Q. Do you have any opinion whether this figure is
`
`portraying Junction 97A in an on state or an off state?
`
` A. It could be either an on state or off state.
`
`Maybe you should -- if you could clarify. What do you
`
`mean by "on state" and "off-state"?
`
` Q. Sure. Well, you see what's indicated as
`
`Element 96; correct?
`
` A. Yes. Or 94A, you mean?
`
` Q. So we do see 94A, which is described as a
`
`junction.
`
` A. Yes.
`
` Q. And what I'm specifically referring to is
`
`Element 96.
`
` A. The transistor.
`
` Q. That's correct. And is that how Janssen '708
`
`describes Element 96, is a transistor? I can
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`specifically refer you to page 5, line 16.
`
` A. I don't see a transistor on line 16.
`
` Q. On page -- I'm sorry, Dr. Liu. There you go.
`
` A. Page 7.
`
` Q. I was probably directing you to the wrong page
`
`on the top and on the bottom. So page 7 of 18, line 16.
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` A. That's right. So Element 96 is a transistor.
`
` Q. Okay. And is it true that transistors
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`generally have on states and off states?
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` A. Depending on the voltages applied, yes.
`
` Q. Depending on voltages applied where?
`
` A. To the gate electrode and relative to the
`
`voltage on the source electrode.
`
` Q. That would define an on state versus an off
`
`state; is that right?
`
` A. Yes.
`
` Q. Okay. And so I had asked you earlier, do you
`
`have any opinion whether Figure 3 of Janssen '708 is
`
`portraying Junction 94A in an on state or an off state.
`
` And just for clarification, what I'm referring
`
`to is whether Figure 3 of Janssen '708 is portraying
`
`Junction 94A with Transistor 96 in an on state or an off
`
`state as you've just described it to me.
`
` A. Okay. So I'm -- your question is not clear to
`
`me because the transistor can have an on state or an off
`
`state depending on the voltages applied across -- to
`
`each of its terminals.
`
` But the junction itself, if you're thinking of
`
`it as a picture element, could independently be
`
`considered to be on, let's say, meaning emitting light,
`
`or not.
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` So are you asking about the pixel -- or the
`
`junction being on or the transistor being on?
`
` Q. The transistor.
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`148
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` A. Okay. So Figure 3 depicts the
`
`interconnections -- circuit configuration of a junction,
`
`and that circuit diagram is valid no matter if the
`
`transistor is in an on state or the off state.
`
` Q. And is Figure 3 a valid diagram no matter
`
`whether Junction 94A is in the on state or the off
`
`state?
`
` MR. ALEXANDER: Objection. Form.
`
` THE WITNESS: So, again, it's not clear to me
`
`when you say the junction is in an on state or an off
`
`state. What does that mean?
`
`BY MR. HELGE:
`
` Q. I'm just using the term in the way you just did
`
`a moment ago, which says "meaning emitting light or
`
`not." So why don't I ask this question again.
`
` Is Figure 3 of Janssen '708 a valid diagram no
`
`matter whether Junction 94A is emitting light or not?
`
` MR. ALEXANDER: Objection to form.
`
` THE WITNESS: So Figure 3 shows an equivalent
`
`circuit for each junction of this display, and that
`
`equivalent circuit can be used to model the electrical
`
`behavior of each junction.
`
` I guess the question is the degree of accuracy
`
`might be different depending on the exact state of the
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`junction, but it is a reasonable equivalent circuit for
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`the junction of a matrix -- you know, video display.
`
`BY MR. HELGE:
`
` Q. What characteristic determines whether
`
`Junction 94A is emitting light or not?
`
` A. The brightness of a picture element depends on
`
`the voltage that is applied to the pixel electrode. So
`
`in this -- in Figure 3, that would be the voltage
`
`difference across Element 100 and across Element 98.
`
` Q. And your answer to that question assumes that
`
`Figure 3 is portraying a liquid crystal display;
`
`correct?
`
` A. My answer?
`
` Q. Yes.
`
` A. Well, pertaining to Figure 3, I suppose the
`
`answer is yes.
`
` Q. Does a liquid crystal display picture element
`
`generate its own light?
`
` A. It depends what you mean by "generate." But it
`
`does allow light to pass through. So, to a consumer, it
`
`would appear to emit light.
`
` Q. Would a person of ordinary skill in the art
`
`ever refer to a liquid crystal display picture element
`
`as generating its own light?
`
` A. I'm not sure. It depends on the context.
`
` Q. Where does light ordinarily come from in a
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`liquid crystal display panel?
`
` A. It comes from a backlight behind the
`
`active-matrix panel. The display itself could include
`
`the backlight. So it could be the backlight and the
`
`active-matrix panel.
`
` Q. And the active-matrix panel is like a camera
`
`shutter that allows light to either pass through or not;
`
`correct?
`
` A. That's correct.
`
` Q. You mentioned a moment ago that Figure 3
`
`displays an equivalent circuit.
`
` Do you see that?
`
` A. Yes, I do.
`
` Q. Does Janssen use those terms, "equivalent
`
`circuit"?
`
` A. I don't recall that it does.
`
` Q. Okay. Can I have you please turn to page 4 of
`
`18 within Janssen '708. Please take a look at line 22,
`
`and let's take a look at from line 22 of page 4 to
`
`line 2 of page 5 of 18 in Janssen '708.
`
` Do you see that that, Dr. Liu?
`
` A. Yes.
`
` Q. Please go ahead and read through that yourself,
`
`and let me know when you're finished.
`
` A. Okay. I'm finished.
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` Q. This portion of Janssen '708 provides a brief
`
`description of each of the figures; is that correct?
`
` A. That's correct.
`
` Q. And does Janssen '708 use the term "equivalent
`
`circuit" anywhere within this brief description of the
`
`figures?
`
` A. It does not.
`
` Q. Are you aware of any instance within
`
`Janssen '708 where the words "liquid crystal" are used?
`
` A. I am not aware.
`
` Q. Do you agree that, in the context of display
`
`technology, the phrase "LC" can refer to liquid crystal?
`
` A. In what context again?
`
` Q. Display technology.
`
` A. Yes, I am.
`
` Q. I'm sorry. Dr. Liu, the question was, do you
`
`agree that, in the context of display technology, the
`
`phrase "LC" can refer to liquid crystal?
`
` A. I do.
`
` Q. Are you aware of any instance in Janssen '708
`
`where the term "LC" is used?
`
` A. I am not.
`
` Q. Are you aware of any instance in Janssen '708
`
`where Janssen labels any electrical symbol as capital R
`
`sub LC?
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` A. I am not.
`
` Q. Are you aware of an instance in Janssen '708
`
`where Janssen refers to any capacitor as capital C
`
`152
`
`sub LC?
`
` A. I am not.
`
` Q. Dr. Liu, I'm going to hand you what's been
`
`premarked as Exhibit 1022 in this matter. This is the
`
`Kozaki reference; is that right?
`
` A. That is correct.
`
` Q. Does this reference look familiar to you?
`
` A. Yes, it does.
`
` Q. You provided an opinion on this reference in
`
`your reply declaration; correct?
`
` A. Opinion? I'd have to look at my declaration.
`
`I did cite this, this reference.
`
` Q. Dr. Liu, did you find this reference for use in
`
`your reply declaration?
`
` A. I don't recall if I was the one who found it,
`
`but I did review it.
`
` Q. When you say you don't recall, I want to
`
`explore that further.
`
` Did you conduct a search of prior art in
`
`conjunction with preparing your reply declaration?
`
` A. Yes, I did.
`
` Q. And do you recall the results that you found as
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`a result of that search?
`
` A. Not in detail. You mean like specific patents
`
`or papers?
`
` Q. Do you recall any? Any specifically?
`
` A. Not specifically. It's been quite a while.
`
` Q. Quite a while. How long ago?
`
` A. I don't even remember the date of the reply
`
`declaration.
`
` Q. Was it after our last deposition in October?
`
` A. Yes, it was.
`
` Q. Do you think it was after Surpass filed its
`
`response in late November of 2015?
`
` A. I don't recall.
`
` Q. So, Dr. Liu, so I can understand, you conducted
`
`a search of prior art. And what specifically were you
`
`looking for in that search?
`
` A. I was looking for, essentially, equivalent
`
`circuits of liquid crystal cells.
`
` Q. Were there any particular characteristics you
`
`were looking for in that search?
`
` A. Looking for publications which show that the
`
`electrical behavior of a liquid crystal cell could be
`
`modeled as a capacitor in parallel -- connected in
`
`parallel with a resistor.
`
` Q. Were you looking for publications that show a
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`liquid crystal cell having the symbols shown in
`
`154
`
`Exhibit E in front of you?
`
` A. Not specifically.
`
` Q. So you don't recall whether Kozaki was found as
`
`a result of your search or somebody else's search; is
`
`that right?
`
` A. That's right.
`
` Q. Do you know if any of the results of your
`
`search were included or cited in your reply declaration?
`
` A. Well, I can't say at this point. I'd have to
`
`go back and look at my notes.
`
` Q. Do you recall any results from your prior art
`
`search that are specifically not included in your reply
`
`declaration?
`
` A. I recall that there was at least one that was
`
`not included because it was slightly after the -- after
`
`2001.
`
` Q. Do you recall any other reason why you would
`
`have discarded the results of your prior art search?
`
`And by "discarding," I mean not including them in your
`
`reply declaration.
`
` A. No. Just the time frame.
`
` Q. Dr. Liu, how else did you come about the
`
`references that were included in your reply declaration?
`
` A. I think it was the attorneys on this case gave
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`me prior art to look at, and I would tell them whether
`
`or not I thought it was relevant.
`
` Q. Do you know who or which attorney conducted
`
`prior art searches for those references?
`
` MR. ALEXANDER: Objection to the assumption
`
`there was searches. But --
`
` THE WITNESS: Yeah. I don't know. They didn't
`
`tell me who found the prior art.
`
`BY MR. HELGE:
`
` Q. So you don't know any details about the
`
`searches that were -- well, I understand that there is
`
`an objection. Let me rephrase that question.
`
` Dr. Liu, I'm going to ask you a few questions
`
`with respect to some of these exhibits that were cited
`
`in your reply declaration with respect to what's shown
`
`in Exhibit E.
`
` And I understand that you have characterized
`
`the symbol of Exhibit E as similar to the symbol being
`
`shown in the figures of Janssen '708. Is that right?
`
` A. That's right.
`
` Q. And the similarity is effectively -- that term
`
`"similar" is being used because the number of zigzags in
`
`the resistor symbol are different; is that right?
`
` A. That's right.
`
` Q. Is there any other difference?
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` A. Not substantial.
`
` Q. So when I say a symbol similar to what's shown
`
`in Exhibit E, you agree that we're talking about simply
`
`156
`
`the number of zigzags?
`
` A. I agree.
`
` Q. Is that okay?
`
` So, Dr. Liu, I'm going to ask you, can you show
`
`me where in Exhibit 1022, Kozaki, Kozaki uses the
`
`identical or similar symbol to what's shown in Exhibit E
`
`in the figures?
`
` A. I cannot.
`
` Q. And why can you not?
`
` A. Because the resistor symbol that is used to
`
`model a liquid crystal picture element does not have a
`
`circle around it.
`
` Q. So Kozaki -- well, actually, can I ask you,
`
`Dr. Liu, are you referring to Figure 7?
`
` A. Yes, I am.
`
` Q. Is that the only equivalent circuit shown in
`
`Kozaki?
`
` A. There's an ideal equivalent circuit shown on
`
`Figure 5.
`
` Q. And does that ideal equivalent circuit use a
`
`resistor symbol to model a liquid crystal element?
`
` A. No, it does not.
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` Q. What is the difference between Figure 5 and
`
`Figure 7 in Kozaki?
`
` A. Figure 7 shows a realistic equivalent circuit
`
`for a liquid crystal cell, and that includes a
`
`resistance -- a resistor in parallel with the
`
`capacitance of the liquid crystal cell.
`
` Q. Am I correct in saying that Kozaki describes
`
`Figure 7 as an actual equivalent circuit of one picture
`
`element?
`
` I'm on page 15 of 19.
`
` A. Yes.
`
` Q. And that actual equivalent circuit includes a
`
`resistor labeled RLC; correct?
`
` A. That is correct.
`
` Q. And that actual equivalent circuit of Figure 7
`
`includes a capacitor labeled as CLC; correct?
`
` A. That's correct.
`
` Q. And you agree that those two labels RLC
`
`and CLC do not appear in Janssen '708; correct?
`
` A. That's correct.
`
` Q. Dr. Liu, am I correct that Kozaki describes
`
`Figure 5 as an ideal equivalent circuit of one picture
`
`element?
`
` A. Yes.
`
` Q. And that ideal equivalent circuit of Figure 5
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`in Kozaki does not display any resistor element at all;
`
`158
`
`correct?
`
` A. That's correct.
`
` Q. And Figure 5 of Kozaki labels the capacitor as
`
`CLC; correct?
`
` A. Correct.
`
` Q. Dr. Liu, do you have any opinion of whether
`
`Figure 5 or Figure 7 of Kozaki are portraying the
`
`picture element with Transistor Q in an on state or an
`
`off state?
`
` A. The Transistor Q portrays a transistor, no
`
`matter what state it is in.
`
` Q. So is it your opinion, Dr. Liu, that Figure 5
`
`and Figure 7 both accurately reflect either an on state
`
`or an off state of Transistor Q?
`
` A. Well, only Figure 7 -- Figure 7 is the more
`
`accurate equivalent circuit for a transistor, no
`
`matter -- well, pixel circuit, no matter if the
`
`transistor is in the on state or the off state.
`
` Q. Would any changes be necessary in Figure 7 to
`
`portray Transistor Q in the on state?
`
` A. Can you repeat the question, please.
`
` Q. I'd like to refine it a little bit.
`
` Would any changes be necessary in Kozaki's
`
`Figure 7 to portray Transistor Q in the on state?
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` A. So explicitly to show that it is on?
`
` Q. That's correct.
`
` A. Well, a transistor in the on state could be
`
`modeled more simply as a resistor; and in an off state,
`
`it could be modeled as an open circuit.
`
` Q. Dr. Liu, I'm handing you what's been premarked
`
`as Exhibit 1023 in this matter. This is the Johnson
`
`reference; correct?
`
` A. That's correct.
`
` Q. Dr. Liu, have you seen this document before?
`
` A. Yes, I have.
`
` Q. When was the last time you reviewed this
`
`document?
`
` A. This morning.
`
` Q. And you cite to this document in your reply
`
`declaration; correct?
`
` A. That's correct.
`
` Q. Dr. Liu, did you find this document, the
`
`Johnson reference, as part of your prior art search?
`
` A. I might have.
`
` Q. Dr. Liu, can you point to anywhere in the
`
`Johnson reference where the same or similar symbol, as
`
`you drew in Exhibit E, is shown in Johnson's figures?
`
` A. I cannot.
`
` Q. And why is that?
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` A. Because the symbol used in the Johnson
`
`reference to represent the liquid crystal resistance is
`
`a simple rectangle rather than a resistor symbol or a
`
`resistor symbol with a circle around it.
`
` Q. Are you referring to Figure 2, Dr. Liu?
`
` A. Yes, I am.
`
` Q. And how do you know that the rectangle that you
`
`just referred to is a resistor?
`
` A. In the specification, Column 2, line 48,
`
`starting on line 47.
`
` "The layer of liquid crystal material 2 (LC
`
`layer) can be described as a parallel circuit of a
`
`resistor and a capacitor as is shown in Figure 2."
`
` Q. And that resistor in Figure 2 is labeled RLC;
`
`correct?
`
` A. That is correct.
`
` Q. And that capacitor in Figure 2 is labeled CLC;
`
`correct?
`
` A. Correct.
`
` Q. Dr. Liu, would you describe Figure 2 as showing
`
`a picture element?
`
` A. Well, it's characterized as an equivalent
`
`circuit diagram of the display cell, shown in Figure 1.
`
` Q. So it's an equivalent circuit diagram of a
`
`display cell of Figure 1; is that right?
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` A. That's right. It's an equivalent circuit of
`
`the display cell in Figure 1, which is a liquid crystal
`
`display cell.
`
` Q. Do you have an opinion whether the display cell
`
`shown in Figure 2 is in an on state or an off state?
`
` A. My opinion is that the equivalent circuit shown
`
`in Figure 2 is valid no matter if the cell is in an on
`
`state or an off state.
`
` Q. Are there any differences that you'd expect to
`
`see in Figure 2 that would indicate specifically if it
`
`is only an on state or only an off state?
`
` MR. ALEXANDER: Objection to form.
`
` THE WITNESS: No, there would not be any
`
`differences.
`
`BY MR. HELGE:
`
` Q. Dr. Liu, I'm going to hand you what's been
`
`marked as Exhibit 1024, and this is the Moriyama
`
`reference.
`
` Dr. Liu, have you seen this document before?
`
` A. Yes, I have.
`
` Q. When was the last time you reviewed this
`
`document?
`
` A. This morning.
`
` Q. And this document is cited in your reply
`
`declaration; correct?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Ex. 2027
`Page 161 of 192
`
`

`
`Deposition of Tsu-Jae King Liu, Volume 2
`Conducted on March 25, 2016
`
`162
`
` A. That's correct.
`
` Q. Did you find this document in your own --
`
`excuse me -- in your own prior art search?
`
` A. I did not find this one.
`
` Q. This one was provided to you by counsel; is
`
`that right?
`
` A. Yes.
`
` Q. Do you kno

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