throbber
1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` - - - - - - - - - - - - - - - - - - - -x
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`SHARP CORPORATION, :
`
`SHARP ELECTRONICS :
`
`CORPORATION, and SHARP :
`
`ELECTRONICS : CaseIPR2015-00913
`
`MANUFACTURING COMPANY : Patent No. 7,420,550
`
`OF AMERICA, INC.,
`
` Petitioners,
`
` v.
`
`SURPASS TECH
`
`INNOVATION LLC,
`
` Patent Owner.
`
` - - - - - - - - - - - - - - - - - - - -x
`
` Deposition of MICHAEL J. MARENTIC
`
` NEW YORK, NEW YORK
`
` WEDNESDAY, NOVEMBER 11, 2015
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` 10:30 A.M.
`
` Job No.: 96195
`
` Pages: 1 - 114
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` Reported By: Nancy Mahoney, RPR/CCR/CLR
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`IPR2015-00887
`Exhibit 2006
`1 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
`
` Deposition of MICHAEL J. MARENTIC, held at the
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` offices of:
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`2
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` AMSTER ROTHSTEIN & EBENSTEIN LLP
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` 90 Park Avenue
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` New York, New York 10016
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` 212.336.8000
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` Pursuant to agreement, before Nancy Mahoney,
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` CCR/RPR/CLR, Notary Public in and for the State of
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` New York.
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`IPR2015-00887
`Exhibit 2006
`2 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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`3
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` A P P E A R A N C E S
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` ON BEHALF OF PETITIONERS SHARP CORPORATION:
`
` MARK BERKOWITZ, ESQUIRE
`
` JUNG S. HAHM, ESQUIRE
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` AMSTER, ROTHSTEIN & EBENSTEIN LLP
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` 90 Park Avenue
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` New York, New York
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` 212.336.8000
`
` ON BEHALF OF PATENT OWNER SURPASS
`
` TECH INNOVATION:
`
` WAYNE HELGE, ESQUIRE
`
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
`
` 8300 Greensboro Drive
`
` McLean, VA 22102
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` 571.765.7700
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2006
`3 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` C O N T E N T S
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`EXAMINATION OF MICHAEL J. MARENTIC PAGE
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`By Mr. Helge 5
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`4
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` E X H I B I T S
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` (Attached to transcript.)
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` MARENTIC PAGE
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` Exhibit 1009 (Previously marked.) 55
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` U.S. Patent Application
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` Publication, US 2003/0048249
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` Exhibit 1007 (Previously marked.)
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` Declaration of 64
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` Michael J. Marentic in
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` Support of Petition for
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` Inter Partes Review of
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` U.S. Patent No. 7,240,550
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` Exhibit 1002 (Previously marked.) 102
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` Certification of Translation
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` 40 Pages
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2006
`4 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` P R O C E E D I N G S
`
` MICHAEL J. MARENTIC,
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` after having been first duly sworn or affirmed to
`
` testify to the truth, was examined and
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` testified as follows:
`
` EXAMINATION BY COUNSEL FOR THE PATENT OWNER
`
` WAYNE HELGE:
`
` Q Good morning, Mr. Marentic.
`
` A Good morning.
`
` Q Good to see you again.
`
` Are you familiar with U.S. Patent No.
`
` 7,420,550?
`
` A Yes.
`
` Q That's the patent at issue in Sharp v.
`
` Surpass Tech Innovation, Case No. IPR2015-00913. Is
`
` that right?
`
` A Yes, that is correct.
`
` Q And you provided a declaration with some
`
` opinions about that patent, correct?
`
` A Yes.
`
` Q We're here this morning to talk about those
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` opinions, correct?
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`5 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` A Yes.
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` Q That's the purpose of your deposition?
`
` A Yes.
`
` Q Mr. Marentic, can you give your full name,
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`6
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` please, for the record.
`
` A Michael James Marentic.
`
` Q Mr. Marentic, we did this just about a
`
` month ago, last deposition. I just want to check.
`
` Is there any reason today that you would not be able
`
` to give true and accurate testimony in this
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` deposition?
`
` A No.
`
` Q Mr. Marentic, I'm also going to read the
`
` same paragraph that I read for you last time into the
`
` record. We talked about this last time. I don't
`
` think there will be any confusion. But this comes
`
` from the Office Patent Trial Practice Guide. The
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` paragraph reads, Once the cross-examination of a
`
` witness has commenced, and until cross-examination of
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` the witness has concluded, counsel offering the
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` witness on direct examination shall not: (a) consult
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` or confer with the witness regarding the substance of
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2006
`6 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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`7
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` the witness' testimony already given, or anticipated
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` to be given, except for the purposes of conferring
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` and whether to assert a privilege against testifying
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` or on how to comply with the Board order; or (b)
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` suggest to the witness the manner in which any
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` questions should be answered.
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` Do you recall that I had read that
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` paragraph for you before?
`
` A I remember hearing a similar paragraph.
`
` Q And you understand the prohibitions against
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` conferring with your counsel today until your entire
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` deposition is concluded, correct?
`
` A I do.
`
` Q Okay, thank you.
`
` Mr. Marentic, has there been any change to
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` your CV since October, since early October?
`
` A No.
`
` Q Have you given any further depositions or
`
` undertaken any further engagements since your last
`
` deposition?
`
` A No.
`
` Q In preparing for this deposition, who did
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`IPR2015-00887
`Exhibit 2006
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` you talk to?
`
` A I talked to attorneys at ARE.
`
` Q Anybody else?
`
` A No.
`
` Q And what documents did you review in
`
` preparation for this deposition?
`
` A My declaration, the '550 patent, the Sharp
`
` reference, and Kamizono.
`
` Q Did you review the petition also?
`
` A No.
`
` Q When was the last time you reviewed the
`
` petition in this case?
`
` A A long time ago. I can't attach a date to
`
` it.
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` Q Was it before it was filed or after it was
`
` filed?
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` A It was after it was filed.
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` Q Did you prepare your declaration without
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` seeing the petition?
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` MR. BERKOWITZ: Objection to form.
`
` A The declaration was prepared --
`
` MR. BERKOWITZ: I'll just interrupt the
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2006
`8 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` witness. To the extent that it involves any
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` privileged communication not to reveal that.
`
` Again, if you can answer the question
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` without revealing any privileged communication,
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` please go ahead.
`
` A I did not see the petition prior to the
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` filing date of March 20 exactly.
`
` Q How many days before March 20, 2015 did you
`
` see your petition -- excuse me. How many days before
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` March 20, 2015 did you first see your declaration?
`
` MR. BERKOWITZ: Objection to form,
`
` relevance.
`
` A I worked on my declaration most of the
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` month of March.
`
` Q In preparation for today's deposition, did
`
` you look at any documents from any of the other IPRs
`
` filed against Surpass?
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` MR. BERKOWITZ: Objection to form, outside
`
` the scope.
`
` A No, not that I'm aware of.
`
` Q Are you aware that there was a deposition
`
` earlier this month -- excuse me, it was actually late
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`9 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` last month -- in a case also against the '550 patent?
`
` A I was not aware of that.
`
` Q So you didn't review a transcript of that
`
`10
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` deposition?
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` A No.
`
` Q Mr. Marentic, when did you last look at
`
` your declaration?
`
` A Last night.
`
` Q Was that the first time you'd reviewed it
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` since it was filed?
`
` A No.
`
` Q You'd been reviewing it in preparation of
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` this deposition over a series of days then?
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` A Yes.
`
` Q You reviewed your declaration against the
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` '843 patent in preparation for your October
`
` deposition, correct?
`
` A Yes.
`
` Q And you reviewed your declaration against
`
` the '550 patent in preparation for this deposition,
`
` correct?
`
` A Correct.
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`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2006
`10 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` Q Having recently reviewed both of those
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` declarations, do you believe that your methodologies
`
` were consistent in those two cases?
`
` MR. BERKOWITZ: Objection to form.
`
` A The last time I looked at the '843
`
` declaration was the date of the deposition. I've not
`
` looked at it since. Would you ask the question
`
` again?
`
` Q My question was whether you felt that your
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` methodologies in these two declarations were
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` consistent.
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` A Consistent with what, each other?
`
` Q Yes.
`
` A I believe so.
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` Q Did you spot any errors in the '550
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` declaration when you reviewed it in preparation for
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` this deposition?
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` A I didn't find any errors. There was a
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` point of clarification and that is about Claim 5 that
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` speaks to the integrated gate drivers. The claim
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` chart relies upon Kamizono, and in the text there was
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` a discussion of Sharp showing integrated gate drivers
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`11 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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`12
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` as well as Kamizono showing integrated gate drivers.
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` Both of those references show it. The claim chart
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` seemed to have a stronger description, and I relied
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` upon Kamizono claim chart, but both Kamizono and both
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` Sharp show integrated gate driver technology as a way
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` of implementing the drivers that drive the gates.
`
` Q So, Mr. Marentic, how would you -- how
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` would you have revised that declaration to capture
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` this clarification that you want to make?
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` MR. BERKOWITZ: Objection to form.
`
` A I may reorganize the material a little
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` different in sequence and paragraphs, but both of
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` them strongly show a path towards integrated gate
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` drivers.
`
` Q So are you saying you would have changed
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` organization but not changed the content?
`
` A Generally, yes.
`
` Q Is there anything you want to add to what I
`
` just said?
`
` A I don't believe so.
`
` Q Are there any other changes to the
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` declaration that you would have made based on your
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`IPR2015-00887
`Exhibit 2006
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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` recent review?
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` A Somewhere was a misspelling. Gate, I think
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` was spelled g-a-t-d, obvious what it was, and I can't
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`13
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` recall where it is.
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` Q Anything else you'd want to change?
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` A No.
`
` Q So everything else is technically accurate
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` and you stand by those words. Is that right?
`
` A That is correct.
`
` Q Mr. Marentic, we're going to talk a lot
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` today I think about drivers, gate drivers, source
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` drivers. Let's talk about source drivers first.
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` Generally speaking, in a LCD panel what is
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` the purpose of a source driver?
`
` A The purpose of the source driver is to
`
` provide an analog voltage on the source lines, source
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` spots, that represents the video input signal.
`
` Q Does the source driver have to drive an
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` analog voltage?
`
` MR. BERKOWITZ: Objection to form.
`
` A For the larger content -- or larger
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` displays displaying video, they would be analog
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`Exhibit 2006
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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` voltage.
`
` Q So it has to be analog voltage?
`
` A There are certain applications where it
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` wouldn't need to be. It could be an on/off, but then
`
` that display wouldn't be capable of displaying gray
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` scale. It would be full on, full off. There aren't
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` displays out there that require just that.
`
` Q And an analog voltage has to be sufficient
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` to do certain things in the pixel. Is that right?
`
` MR. BERKOWITZ: Objection to form.
`
` A The output range of an analog output needs
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` to match the liquid crystal cell characteristics.
`
` Q And what goes into those characteristics,
`
` what factors are there?
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` A Making sure that the cell can be driven to
`
` a full off state and a full on state. So, for
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` instance, it wouldn't be biased in such a way that
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` the cell is always on or the cell is always off.
`
` Q Well, let me ask you this. Is it common
`
` for an LCD panel to include a storage capacitor?
`
` MR. BERKOWITZ: Objection to form.
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` A There is a number of components that appear
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`14 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` as capacitors. Certainly the liquid crystal material
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` itself between the two electrodes appears as a
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` capacitor.
`
` Q How would you describe that, that liquid
`
` crystal material acting as a capacitor?
`
` MR. BERKOWITZ: Objection.
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` Q Is there a term that we can use to describe
`
` that?
`
` MR. BERKOWITZ: Objection to form. Please
`
` let him finish the answer.
`
` A There is a second capacitor in each pixel,
`
` a holding capacitor that is formed during the process
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` of forming the TFTs. So there's two capacitors in
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` parallel, and then there's an array of parasitic
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` capacitances throughout the panel. The easiest to
`
` consider would be the crossover of a gate and a
`
` source bus at that intersection would be a parasitic
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` capacitance.
`
` Q Is there a term we use to describe -- or we
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` can use to describe the capacitance resulting from
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` the LC material?
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` A Clc.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`15 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` Q And that would be a liquid crystal
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`16
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` capacitance?
`
` A Yes.
`
` Q And then what about the hold capacitor?
`
` MR. BERKOWITZ: Objection to form.
`
` A That could be called -- I'd like to be
`
` consistent. Sometimes it's called S shunt. The '550
`
` uses the Cs shunt.
`
` Q Is that the same thing as a storage
`
` capacitor?
`
` A Yes.
`
` Q How is the storage capacitor charged within
`
` a frame?
`
` A It's in parallel with the Clc.
`
` Q How do you get a potential difference
`
` across that storage capacitor?
`
` MR. BERKOWITZ: Objection to form,
`
` foundation.
`
` A Through the drain of a TFT on that pixel.
`
` Q And where does the drain get voltage to
`
` charge the storage capacitor?
`
` MR. BERKOWITZ: Objection to form,
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2006
`16 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` foundation.
`
` A There is a voltage presented by a driver
`
` output to a source bus and a gate signal will turn on
`
` the TFT and allow charging of the parallel Clc and Cs
`
` capacitance.
`
` Q You said just a moment ago a driver. Would
`
` that be a source driver?
`
` MR. BERKOWITZ: Objection to form.
`
` A The term source driver or data driver are
`
` equivalent for purposes of this patent. The driver
`
` output would generate the voltage that is present on
`
` the source bus and that output could be part of
`
` another device that's also called a driver and that
`
` driver would be a monolithic integrated circuit. So
`
` the term driver can refer to an integrated circuit or
`
` a driver can refer to a single output that is present
`
` within an integrated circuit or IC.
`
` Q When you say output, you're talking about
`
` that analog voltage?
`
` A A circuit that outputs the analog voltage
`
` that is presented to the TFT array.
`
` Q And that is the analog voltage, correct, in
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`17 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` a video displaying LCD?
`
` A In a display displaying video, that would
`
` be an analog voltage or stepped in increments of say
`
` 256 grade levels.
`
` Q Did you say "or stepped in increments"?
`
` A Yes.
`
` Q What would be stepped in increments?
`
` A The output voltage of a stage or a single
`
` output.
`
` Q What is a stage?
`
` A A driver output. There is a couple of ways
`
` of supplying the video. One would be an infinite
`
` number of combinations between two voltages. The
`
` other would be a set of commonly 256 gray levels
`
` between two voltages, but for purposes of the drivers
`
` that we're talking about, it's sort of -- driver
`
` meaning IC or driver meaning output stage, that's a
`
` level of detail that really isn't discussed in these
`
` patents.
`
` Q You had me confused now because you've
`
` talked about a driver, a driver stage and a stage
`
` separately in all different ways. Can you clarify
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`18 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` the meaning among those three things?
`
` A Well, the '550 is a little confusing. It
`
` uses drivers to mean discrete integrated circuits,
`
` and it also uses the term driver to mean an output,
`
` an output stage of which there are multiple within an
`
` integrated circuit driver.
`
` So, yes, it is confusing as a result of the
`
` language that was used in the '550 and also generally
`
` the terminology used among technologists and the
`
` context would be obvious whether it was the IC or a
`
` single output.
`
` Q And so when you talk about a single output,
`
` are you talking about a single output from an IC
`
` driver?
`
` A An output could mean that, yes.
`
` Q How have you been using the term?
`
` A I will usually -- in the declaration I was
`
` careful to call out monolithic or chip versus output
`
` or driver output. I believe I am consistent in doing
`
` that.
`
` Q I want to understand how you've been using
`
` it already this morning. What are you referring to
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`19 of 272
`
`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` when you talk about an output?
`
` MR. BERKOWITZ: Objection to form.
`
` A An output is a port or a signal point that
`
` is present within an integrated circuit.
`
` Q So there could be multiple outputs on one
`
` integrated circuit?
`
` A There frequently are, yes.
`
` Q And the distance between those outputs, is
`
` that measured in pitch?
`
` MR. BERKOWITZ: Objection to form,
`
` foundation.
`
` A The distance between them? I'd have to
`
` scratch my head. I'm not sure that's a relevant
`
` parameter for driver outputs.
`
` There is a pitch but if I were to be buying
`
` drivers, I would look at a number of electrical
`
` characteristics and pitch would be low in
`
` consideration.
`
` Q Do you know what pitch means in a driver
`
` context?
`
` A I do.
`
` Q What does that mean?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`20 of 272
`
`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` A To me it means the distance between the
`
` center line of a output pad between adjacent driver
`
` stages or driver outputs.
`
` Q In the 2004 time frame, are you aware of
`
` what the standard pitch was for driver ICs?
`
` MR. BERKOWITZ: Objection to form,
`
` relevance, scope.
`
` A I don't have that number on the top of my
`
` head.
`
` Q Did you investigate that issue when you
`
` were preparing your declaration?
`
` MR. BERKOWITZ: Objection to form.
`
` MR. HELGE: What's wrong with the question?
`
` MR. BERKOWITZ: He already said he's not
`
` familiar with it.
`
` MR. HELGE: I'm asking if he investigated
`
` it in preparation for his deposition. I'd like you
`
` to answer it.
`
` MR. BERKOWITZ: You asked him earlier
`
` before this deposition.
`
` MR. HELGE: And I'm asking him in
`
` preparation for his declaration.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`21 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` MR. BERKOWITZ: I didn't instruct -- he can
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`22
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` answer.
`
` MR. HELGE: One person talking at a time,
`
` please.
`
` Q Mr. Marentic, can I get an answer to that
`
` question, please?
`
` A I did not concern myself with pitch during
`
` this declaration. The term pitch, although used in
`
` the art, is not in the claim language of the '550
`
` patent, so I didn't concern myself with it.
`
` Q We talked earlier about different terms for
`
` source driver, and I think you mentioned data driver
`
` and source driver. Is that right?
`
` A Yes.
`
` Q Are there other terms that we could use for
`
` that same concept, those are the most common terms?
`
` Are they ever called column drivers?
`
` A Occasionally.
`
` Q Is there any difference between a source
`
` driver, a data driver or a column driver, in your
`
` estimation?
`
` MR. BERKOWITZ: Objection to form.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2006
`22 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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`23
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` A For a liquid crystal display, a large area
`
` displaying video the term that I've always heard is
`
` source or data driver. Column driver could be used.
`
` It's frequently used in other display technologies
`
` like plasma or polymer dispersed liquid crystal or in
`
` film electroluminescence or super-twist nematic, STN
`
` technology.
`
` Q So in the context of LCD technology, do you
`
` believe that a source driver and a data driver are
`
` synonymous?
`
` A Generally, yes.
`
` Q Is there an instance where they wouldn't be
`
` synonymous?
`
` A If you have some test cases, I'd like to
`
` look at them.
`
` Q I just want to understand in your
`
` experience.
`
` A In terms of the '550 patent, the patent
`
` calls out data drivers and then the claim calls out
`
` source driver, and to me the source driver refers to
`
` the data driver. Within this ball of confusion of is
`
` it an integrated circuit or is it just a driver
`
`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2006
`23 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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`24
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` output.
`
` Q In your experience, is one of those terms
`
` better than the other, is source driver better than
`
` data driver or vice versa?
`
` MR. BERKOWITZ: Objection to form.
`
` A Different factories will tend to call --
`
` use one term or the other term. The IC manufacturers
`
` will use both terms, I believe, also. In the context
`
` of larger area display displaying video with a TFT
`
` active matrix array, the source and the data driver
`
` would be equivalent terms.
`
` Q In LCD display, do the LC molecules emit
`
` light?
`
` A No.
`
` Q What do they do with respect to light?
`
` A They interact with polarized light and
`
` modulate the amount of light that passes through a
`
` liquid crystal cell. The light is generated for
`
` these types of displays by backlight, and the liquid
`
` crystal pixel modulates the amount of light that
`
` reaches the viewer's eyes.
`
` Q Is it accurate to say that liquid crystal
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`24 of 272
`
`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
`
` molecules act as a sort of shutter to allow light
`
`25
`
` passing through it?
`
` A A variable shutter.
`
` Q Have you heard of the term ramp retrace in
`
` the context of LCD technology?
`
` MR. BERKOWITZ: Objection, relevance,
`
` scope.
`
` A Sitting here today, I can't recall that
`
` term.
`
` Q It's not familiar to you?
`
` A I can't recall it right now.
`
` Q How about hold drive?
`
` MR. BERKOWITZ: Objection to form,
`
` relevance and scope.
`
` A Well, Sharp reference uses a sample and
`
` hold method.
`
` Q What does that mean, sample and hold?
`
` A A video signal is sampled at a specific
`
` point in time, and that sample is held on a storage
`
` capacitor.
`
` Q What happens if you don't have a storage
`
` capacitor in a pixel, can it hold that signal in the
`
`PLANET DEPOS
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`IPR2015-00887
`Exhibit 2006
`25 of 272
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`

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`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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`26
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` pixel?
`
` MR. BERKOWITZ: Objection to form.
`
` A There is an additional capacitor outside
`
` the Clc and the Cs parallel combination. The sampling
`
` device will have an additional hold capacitor.
`
` Q And so am I correct in saying that that's
`
` the third capacitor that we're talking about within a
`
` pixel region?
`
` A It's the third discrete capacitor that
`
` we've been talking about. There's some scattered
`
` parasitics that are always present but it would be a
`
` third discrete capacitor.
`
` Q Have you seen a hold capacitor modeled in
`
` any of the documents that you reviewed for this
`
` deposition?
`
` MR. BERKOWITZ: Objection to the form.
`
` A To me modeled means a spice simulation.
`
` And no, I've seen no SPICE simulation for this area
`
` of the '550 patent.
`
` Q Have you seen any graphic representations
`
` of the hold capacitor in any of these documents that
`
` you reviewed for deposition?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`26 of 272
`
`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
`
` MR. BERKOWITZ: I'm sorry, could you read
`
`27
`
` that back.
`
` (Pending question read.)
`
` A The Sharp reference has some capacitors
`
` that are shown. I refer to them in my report as part
`
` of the sample hold circuit.
`
` Q We'll have to come back to that in a little
`
` bit.
`
` Any others that you recall?
`
` A The Sharp reference has additional
`
` embodiments where there's extra additional
`
` capacitors.
`
` Q Is that it?
`
` A That's all I recall.
`
` Q So you've been talking about what you've
`
` referred to as a sample and hold circuit. Is that
`
` right?
`
` A That's what the Sharp reference describes,
`
` a transistor and a capacitor.
`
` Q Do you have any professional opinion as to
`
` whether sample and hold is the same thing as a hold
`
` drive?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2006
`27 of 272
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`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
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` MR. BERKOWITZ: Objection to form. I've
`
` not really heard the term hold drive. It doesn't
`
` ring a bell.
`
` Q In your CV you talk about Alien Technology.
`
` Do you remember we talked about that last month?
`
` A We did.
`
` Q It says in your CV that you were involved
`
` with the design of custom drivers. Is that right?
`
` A That's correct.
`
` Q What kind of drivers were those, custom
`
` drivers?
`
` A Those were drivers designed by engineers at
`
` Alien. They were for organic LED, they were for
`
` cholesteric liquid crystal and for polymer dispersed
`
` liquid crystal. They also had the additional
`
` requirement that they be roughly square or just
`
` slightly rectangular, and Alien Technology had a
`
` method of assembling silicon dye on to a substrate
`
` called fluidic self-assembly. The driver ICs, or
`
` chips, were made on a standard wafer run through
`
` standard wafer processing. They were etched and
`
` broken and the result was their shape looked like a
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-00887
`Exhibit 2006
`28 of 272
`
`

`
`Deposition of Michael J. Marentic
`Conducted on November 11, 2015
`
` truncated pyramid with the circuitry transistors
`
` diffused in at the top of the truncated pyramid. The
`
`29
`
` circuits were held in a fluid and passed over a
`
` substrate with the opposite shape of a pyramid,
`
` dimples, and the dye would reliably and quickly
`
` insert themselves upside down into the dimples, and
`
` we could do tremendous number of assemblies per
`
` minute. I don't remember the number, but million
`
` kind of number. And these displays were ultralow
`
` cost and they were flexible, typically for a credit
`
` card or additional security for a chipped credit
`
` card.
`
` Q So Alien Technology produced these custom
`
` drivers for various types of displays. Were you
`
`

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