UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`1
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`- - - - - - - - - - - - - - - x
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`LG DISPLAY CO., LTD., :
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` Petitioner :
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`v. : Case IPR2015-00885
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`SURPASS TECH INNOVATION LLC, : Patent 7,202,843
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` Patent Owner :
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` Deposition of RICHARD ZECH, PH.D.
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` Washington, D.C.
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` Friday, November 13, 2015
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` 9:30 a.m.
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`Job No.: 96195
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`Pages 1 through 158
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`Reported by: Marilyn Feldman, RPR
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`IPR2015-00887
`Exhibit 2007
`Page 1 of 374
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`
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`1
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`- - - - - - - - - - - - - - - x
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`LG DISPLAY CO., LTD., :
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` Petitioner :
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`v. : Case IPR2015-00885
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`SURPASS TECH INNOVATION LLC, : Patent 7,202,843
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` Patent Owner :
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`- - - - - - - - - - - - - - - x
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` Deposition of RICHARD ZECH, PH.D.
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` Washington, D.C.
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` Friday, November 13, 2015
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` 9:30 a.m.
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`Job No.: 96195
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`Pages 1 through 158
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`Reported by: Marilyn Feldman, RPR
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`IPR2015-00887
`Exhibit 2007
`Page 1 of 374
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`
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Deposition of RICHARD ZECH, PH.D., held at
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`the offices of:
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`2
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` MAYER BROWN LLP
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` 1999 K Street, NW
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` Washington, D.C. 20006-1101
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` 202.263.3154
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` Pursuant to agreement, before Marilyn
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`Feldman, Registered Professional Reporter and Notary
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`Public in and for the District of Columbia.
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`IPR2015-00887
`Exhibit 2007
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 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 PETITIONER LG DISPLAY:
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` WILLIAM J. BARROW, ESQUIRE
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` MAYER BROWN LLP
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` 1999 K Street, NW
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` Washington, D.C. 20006-1101
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` 202.263.3154
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` ON BEHALF OF PATENT OWNER SURPASS TECH:
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` WAYNE HELGE, ESQUIRE
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` DAVIDSON BERQUIST JACKSON & GOWDEY LLP
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` 8300 Greensboro Drive
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` Suite 500
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` McLean, VA 22102
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` 571.765.7708
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`IPR2015-00887
`Exhibit 2007
`Page 3 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` C O N T E N T S
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`EXAMINATION OF RICHARD ZECH, PH.D. PAGE
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` By Mr. Helge 5, 154
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` By Mr. Barrow 140
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`4
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` E X H I B I T S (marked previously)
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` EXHIBITS ATTACHED:
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`LG Display Exhibit 1001 Shen patent 7,202,843
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`LG Display Exhibit 1010 Lee, Korean translation
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`LG Display Exhibit 1011 Declaration of Richard Zech
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`IPR2015-00887
`Exhibit 2007
`Page 4 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` P R O C E E D I N G S
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` RICHARD ZECH, PH.D.
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`having been duly sworn, testified as follows:
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` EXAMINATION BY COUNSEL FOR PATENT OWNER
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`BY MR. HELGE:
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` Q Good morning, Dr. Zech.
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` A Good morning, sir.
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` Q Dr. Zech, you provided an opinion
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`regarding U.S. patent 7,202,843 in this case; is
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`that right?
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` A That's correct.
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` Q This case that I'm referring to is LG
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`Display Company v. Surpass Tech Innovation LLC,
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`correct?
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` A Correct.
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` Q And the case number is IPR2015-00885,
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`correct?
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` A Well, I'll take your word for it.
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` Q I understand.
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` A I didn't happen to memorize that.
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` Q Fair enough. We are here for a deposition
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`on your declaration; is that right?
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`IPR2015-00887
`Exhibit 2007
`Page 5 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` A I believe that is true, yes.
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` Q Have you seen the notice of deposition for
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`6
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`this case?
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` A I don't believe I have.
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` Q Are you appearing voluntarily?
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` A Oh, yes, yes indeed.
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` Q And you are appearing probably pursuant to
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`that notice of deposition?
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` A I'm sure that was the case.
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` MR. BARROW: Yes.
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` Q Thank you. Dr. Zech, can you please state
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`your full name for the record?
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` A Be happy to. Richard, initial G, last
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`name Zech, Z-e-c-h, 130 Cresta Road, C-r-e-s-t-a,
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`Colorado Springs, Colorado 80906, (719) 633-4377.
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` Q Dr. Zech, I am going to stop you there.
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`What I don't want is any more information that you
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`might consider private.
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` A You are entitled to my full contact
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`information, although you have my card, but for the
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`record to make sure I'm the same person.
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` Q Thank you. I take it you have been
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`IPR2015-00887
`Exhibit 2007
`Page 6 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`deposed before?
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` A Once or twice.
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` Q Probably more than that; is that right?
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` A Many times more.
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` Q Probably at the beginning of all those
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`depositions the attorney who has been asking you
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`questions has stated some ground rules for the day;
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`is that right?
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` A Absolutely.
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` Q One of those ground rules that I think we
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`are doing a pretty good job at so far is only one
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`person can talk at a time because the reporter can
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`only take the transcript of testimony from one
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`person at a time. Do you understand that?
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` A I understand.
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` Q Dr. Zech, are you taking any medication or
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`do you have any other reason why you may not be able
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`to give true and accurate testimony today?
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` A Other than old age.
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` Q Understood.
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` A I haven't been taking any medicines.
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` Q And you can give true and accurate
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`IPR2015-00887
`Exhibit 2007
`Page 7 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`testimony today?
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` A I certainly hope I can. I'll do my best.
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` Q You'll let me know if you feel you are not
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`8
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`able to answer a question?
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` A Absolutely.
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` Q And you'll let me know if you have a
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`question about anything I have asked you?
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` A Absolutely.
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` Q One other thing that has come up recently,
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`but I suspect it won't come up here, is if I ask you
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`a question, I will need an affirmative verbal
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`response because head-nodding and shaking of the
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`head won't get onto the reporter's transcript.
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` A I understand. I won't do it on purpose
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`but as the day goes on I may wear out and start
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`doing something like that. Please bring me up short
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`if I do.
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` Q Absolutely. Thank you. Dr. Zech, this is
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`a case before the Patent Tral and Appeal Board; do
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`you understand that?
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` A Yes, I do.
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` Q Have you been before the Patent Tral and
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`IPR2015-00887
`Exhibit 2007
`Page 8 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`Appeal Board or been offered as an expert before the
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`Patent Tral and Appeal Board before?
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` A No more than six times in the last year.
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` Q Have you been deposed in any of those
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`cases?
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` A All but this one.
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` Q Okay, good. Something I'm going to read
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`to you comes from the Patent Office Trial Practice
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`Guide and maybe this has been read to you before,
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`maybe not, but I want to make sure you understand
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`the particular rules of this forum. "Once the cross
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`examination of a witness has commenced and until
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`cross examination of the witness has concluded,
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`counsel offering the witness on direct examination
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`shall not (A), consult or confer with the witness
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`regarding the substance of the witness's testimony
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`already given or anticipated to be given except for
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`the purpose of conferring on whether to assert
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`privilege against testifying or on how to comply
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`with a board order; or (B), suggest to the witness
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`the manner in which any questions should be
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`answered."
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`IPR2015-00887
`Exhibit 2007
`Page 9 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Do you understand the paragraph as I have
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`just read it?
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` A That's the way it has been for the prior
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`five depositions.
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` Q Great. And so the way the board
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`interprets this is that even when I have concluded
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`asking questions and when your counsel may be
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`preparing to ask you additional questions during
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`this deposition, this prohibition against conferring
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`with your counsel still applies.
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` A Okay.
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` Q And so until we actually close everything
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`up with the reporter and shut the deposition down
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`for the day, this prohibition still applies. Does
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`that make sense?
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` A I understand it and I'll respect it.
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` Q Thank you. Dr. Zech, you submitted your
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`CV in this case back in March; is that about right?
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` A Yes, I believe so, about the same time
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`that I submitted the declaration.
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` Q Right. Is that CV still accurate?
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` A Probably not because, as I say, I have
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`IPR2015-00887
`Exhibit 2007
`Page 10 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`done depositions on five of the declarations I
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`submitted at about the same time I submitted the one
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`for LGD. But other than saying here's the case,
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`here is the fact that I did a deposition, probably
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`not very informative, but I'd be glad to supply Mr.
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`Barrow with an up-to-the-minute resume if that would
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`be helpful.
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` Q I'll just ask you, have you added any more
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`engagements to your CV since March?
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` A Yes, I have, yes.
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` Q Do you recall the case names or the
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`patents at issue in any of those cases?
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` A The only current activity of mine has to
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`do with a litigation that hasn't been filed yet,
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`it's prelitigation.
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` Q In that case please don't tell me anymore.
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` A I didn't intend to.
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` Q Thank you. So is that the sole addition
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`you think from your CV?
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` A I'm embarrassed to say I can't remember.
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` Q Why don't we do this. I'm going to hand
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`you exhibit 1011. Dr. Zech, does this document look
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`IPR2015-00887
`Exhibit 2007
`Page 11 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`familiar to you?
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` A It sure does.
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` Q Is that your name on the cover?
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` A It sure is.
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` Q If you were to turn to page -- and this is
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`going to be a little bit tricky because some of them
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`are numbered sequentially and some of them have
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`these Bates numbers, but it looks like page 48 on
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`the bottom middle and page 654 using the Bates
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`numbers.
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` A Yes, sir.
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` Q Is that your signature there?
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` A It is indeed.
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` Q This is going to be page 662 and it's page
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`7 of 26 on your CV which is just a few more pages
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`beyond where we were just looking.
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` A I have the first page, for example.
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` Q Looking at page 7 of 26.
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` A Thank you. Yes, sir.
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` Q Do you see the top, this looks like your
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`litigation support experience, correct?
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` A Yes, sir, it is.
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`IPR2015-00887
`Exhibit 2007
`Page 12 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Q At the top you have the Intellectual
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`Ventures case versus Canon and that appears to be
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`your most recent engagement listed on this paper.
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` A Oh, actually that engagement came in
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`January of 2015 and this following, the one with Mr.
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`Barrow here, so at the bottom of each section I have
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`the starting date and whether or not I have
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`terminated my work with this particular customer,
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`and every place you see the TBDs -- oh, this is from
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`February, this is out of date unfortunately -- all
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`of these TBDs with the exception of this matter I
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`have been deposed on.
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` Q I see.
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` A Yes. I have not -- it wouldn't do you any
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`good because I have not revealed anything about the
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`current work and I couldn't and shouldn't so it
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`wouldn't be on here anyway. But if you'll just --
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` Q When you say current work, you mean the
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`prelitigation work.
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` A Prelitigation.
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` Q Understood. Thank you. So that
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`prelitigation is the only new engagement since this
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`IPR2015-00887
`Exhibit 2007
`Page 13 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`Intellectual Ventures v Canon case; is that right?
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` A Yes, to the best of my recollection. I
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`have been offered by one of the brokers, DDW
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`Brokers, expert witness brokers, probably 5, 6, 10
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`people, but they tend to get in early and the
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`lawyers won't be looking for an expert for 6 or 10
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`months from now.
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` Q Right, I understand. Dr. Zech, what did
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`you do to prepare for this deposition today?
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` A Well, I'll work backwards. Yesterday I
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`spent the day with Mr. Barrow, we went over my
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`declaration, the '843 patent, some other documents,
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`and prior to that I reviewed -- oh, yesterday
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`included review of the Lee not patent but the
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`application and translation from the Korean. Prior
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`to that -- well, I didn't have a lot of time, so for
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`the last week or so, maybe two weeks, at a low level
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`I reviewed my materials on LCD products, did quick
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`scans through the declaration, the patents, other
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`documents that I relied on.
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` Q So let's start with the people that you
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`spoke with. You spoke with Mr. Barrow yesterday?
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`IPR2015-00887
`Exhibit 2007
`Page 14 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` A Yes.
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` Q Did you speak with any other attorneys?
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`15
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` A I did. Is it Kamir?
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` MR. BARROW: Kfir.
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` A Kfir, yes, he stopped in briefly. All we
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`did was say hello, no real interaction. Mr. Barrow
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`has been my primary contact on this in all regards.
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` Q Yesterday was the first day you met in
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`person with him?
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` A No. I met in person with him in either
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`November or December of last year, I don't remember
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`when.
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` Q Okay. We don't need to get into that.
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`Thank you. Did you talk with any nonattorneys about
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`this case prior to this deposition?
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` A No, sir.
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` Q Dr. Zech, let's go through some of the
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`documents that you mentioned.
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` A Okay.
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` Q I want to get my hands on what you
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`reviewed. So yesterday you looked at the '843
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`patent; is that right?
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`IPR2015-00887
`Exhibit 2007
`Page 15 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` A Yes.
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` Q You looked at your declaration?
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` A Yes.
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` Q You looked at the Lee translation?
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` A Yes.
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` Q Do you speak Korean?
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` A No, but my wife does.
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` Q Do you read Korean?
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` A No.
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` Q Did you talk to your wife at all about the
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`contents of the original Lee documents in Korean?
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` A No, not to my wife.
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` Q Did you talk to anybody else about the
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`contents of that document in Korean?
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` A Yes.
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` Q Whom did you talk to?
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` A My niece and my nephew.
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` Q Are they Korean speakers?
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` A Yes.
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` Q Are they able to read Korean?
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` A Yes.
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` Q What was the nature of your conversation
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`IPR2015-00887
`Exhibit 2007
`Page 16 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`with your niece and your nephew about the Korean
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`documents?
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` A Well, mainly -- it involved entirely the
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`figures and I just wanted to make sure that my
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`guesses about what these Korean words represent were
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`correct.
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` Q Okay. Did you compare what you were told
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`by them to what you found in the English translation
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`of Lee?
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` A Yes, I did.
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` Q Did that information that you received
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`from your niece and your nephew match what you found
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`in the translation?
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` A They were spot on. I can't tell you how
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`impressed I was with the way they translated these
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`things. It included a lot of technical terms.
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`Neither one of them is a college graduate and have
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`no technical background so I was impressed.
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` Q When you say they translated, you are
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`referring to your niece and nephew?
`
` A Yes. Just the figures.
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` Q Did you have them translate all of the
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`IPR2015-00887
`Exhibit 2007
`Page 17 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`figures with you?
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` A I think we went through most all, but I
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`really can't recall at this point.
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` Q So you are not sure how many figures you
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`looked at with them?
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` A There were quite a few as I recall but I
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`couldn't answer your question and say there were 20
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`of them, did I do all 20 or just 15 or what have
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`you. I'm pretty sure we did them all.
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` Q And you didn't spot any errors during that
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`process?
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` A No, that wasn't my mission. As far as I
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`know, there were no technical errors, although I
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`wasn't purposely trying to seek them out.
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` Q Dr. Zech, I just want to understand what
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`you just said. You said you weren't trying to seek
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`out any errors; is that right?
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` A Yes. My mission was not to find errors
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`but to get the English meaning of the words so at
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`some future date if I chose to review it in detail,
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`say I didn't get a certified English translation,
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`I'd still be able to work with them.
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`IPR2015-00887
`Exhibit 2007
`Page 18 of 374
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`
`
`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Q How did you get the Lee documents in the
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`first place?
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` A My guess is it came from Mr. Barrow.
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` Q You don't recall looking for it yourself
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`then?
`
` A Well, I do have things from Lee but they
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`are patents, not that Korean application. I have
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`U.S. patents that have been issued to Lee.
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` Q Did you search for those yourself and find
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`them?
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` A I found those on my own.
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` Q Was that before or after you received the
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`Lee reference we are talking about in this case?
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` A I don't really recall.
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` Q But you didn't rely on any other Lee
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`reference in your declaration, correct?
`
` A No.
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` Q And you didn't identify it in appendix B
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`which lists the documents that you relied upon in
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`this case, right?
`
` A Yes. I did not use anything other than
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`the Lee translation.
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`IPR2015-00887
`Exhibit 2007
`Page 19 of 374
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`
`
`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Q And so you found that your niece and
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`nephew's translations matched what is in the English
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`20
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`translation of Lee, correct?
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` A Very close, very close.
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` Q At any point was there a situation where
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`you deferred to your niece and nephew rather than
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`the English translation that we have in this case?
`
` A No.
`
` Q So the English translation is the primary
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`source of your understanding of Lee; is that right?
`
` A Yes, sir.
`
` Q You mentioned, if I recall, when you were
`
`discussing the work you did yesterday that you
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`looked at some other papers. Do you recall what
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`those other papers are?
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` A Well, give me a moment to reflect and
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`maybe I can recall them all. We have already
`
`mentioned the Lee translation, the '843 patent, my
`
`declaration. I suspect we might have looked at the
`
`petition coming from LGD. That's all I can
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`remember, sir. Sorry.
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` Q Dr. Zech, did you look at all at any
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`IPR2015-00887
`Exhibit 2007
`Page 20 of 374
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`
`
`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`21
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`documents from other papers filed with the Patent
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`Trial and Appeal Board relating to the '843 patent?
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`I can give you some examples if you like.
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` A No, that's okay. The only thing I looked
`
`at was the Sharp petition.
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` Q The Sharp petition?
`
` A Yes, it's in the public domain, I found it
`
`on the Internet.
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` Q You looked at that yesterday?
`
` A No, I didn't.
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` Q In the past?
`
` A Sorry?
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` Q In the past?
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` A Yes, before I did my declaration.
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` Q You understand that Sharp petition was
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`denied on most grounds, correct?
`
` A Yes, I got that impression from some of
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`the documentation. Oh, one other thing was your
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`document -- having a senior moment here -- it was
`
`your reply, your response, and it was very clear to
`
`me that Sharp had been denied.
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` Q Have you looked at any deposition
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`Exhibit 2007
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`transcripts from other cases against Surpass Tech
`
`Innovation before the Patent Trial and Appeal Board?
`
` A No, sir. Until this case I had never
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`heard of Surpass before.
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` Q I will tell you, I can represent to you
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`recently other depositions were taken of experts in
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`related cases dealing with the '843 patent,
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`depositions of experts provided by petitioners, and
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`so I was curious if you had looked at any of the
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`transcripts of those depositions and this would have
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`been in the last month or so.
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` A I understand your question. The answer is
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`no. Mr. Barrow did not share those things with me.
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`I didn't even know those depositions had taken
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`place.
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` Q Thank you. I am going to go back to last
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`week because you mentioned things that happened last
`
`week. You said you looked at some LCD materials and
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`I'm curious what those materials were.
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` A Basically industry papers. The field of
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`liquid crystal displays, whether used for monitors
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`or televisions, is very complex and because I was
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`IPR2015-00887
`Exhibit 2007
`Page 22 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`working on other things as my resume indicates,
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`optical data storage drives, scanners, etc., and
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`really it's been a year since I have worked on this
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`case, I just wanted to refresh my memory.
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` Q So that was primarily for general
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`understanding of the technology?
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` A Exactly.
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` Q Did you rely on any of those materials in
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`preparing your declaration?
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` A I don't believe so.
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` Q Because I know they are not listed in
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`appendix B.
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` A No. In something like a declaration --
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`and this year wasn't the first time I have done a
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`declaration -- I'm basically instructed to stick
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`closely to the program, that is you have patents,
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`you may have some other supporting documents, and I
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`should wait until my expert report, if there is
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`going to be one, to perhaps introduce some of this
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`material.
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` Q Okay. When you were reviewing those LCD
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`materials, did you come across any disclosure that
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`IPR2015-00887
`Exhibit 2007
`Page 23 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`would contradict what you said in your declaration?
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` A I don't believe so.
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` Q When you were reviewing those other LCD
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`materials, did you find any disclosure that may
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`contradict what you saw in Surpass's reply in the
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`Sharp case?
`
` A Well, I don't really remember much about
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`your reply to the Sharp case so my answer would be
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`no.
`
` Q And it's no because you don't really
`
`remember what --
`
` A I really don't. I try not to depend on
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`other people. If I say something to you, it's
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`because I'm saying it to you, not someone else.
`
` Q Okay. Thank you, Dr. Zech.
`
` A You're welcome.
`
` Q You mentioned also some other documents
`
`that you reviewed last week. Do you recall any of
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`those other documents?
`
` A Pretty much what we talked about yesterday
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`and the tutorial material, as I call it.
`
` Q What is that, doctor?
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`IPR2015-00887
`Exhibit 2007
`Page 24 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` A Those were the industry papers and what
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`have you, books, I have a number of books.
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` Q Dr. Zech, when was the last time you
`
`looked at the prosecution history for the '843
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`patent?
`
` A I know I have it and it had to be about a
`
`year ago.
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` Q You looked at it in preparation for your
`
`declaration, right?
`
` A Oh, yes.
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` Q I know it is listed on appendix B. So you
`
`are aware of the '843 patent issue in the Patent
`
`Office, are you not?
`
` A I am.
`
` Q Do you recall seeing a document called
`
`Reasons For Allowance that was issued by the
`
`examiner during prosecution?
`
` A Only most vaguely.
`
` Q Do you recall that the examiner commented
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`on another reference called Ham, H-a-m, and the
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`reasons for allowance?
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` A No.
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`IPR2015-00887
`Exhibit 2007
`Page 25 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Q And you don't recall looking for the Ham
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`reference in preparation for your declaration at
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`all?
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` A I really don't recall. It's been a year
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`ago and at my age I not only can't remember if I had
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`breakfast but if I did, what I had.
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` Q Understood. So Dr. Zech, let me ask you
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`this. In preparing your declaration, at any point
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`did you feel that you should compare the art that
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`you were relying on in this declaration against art
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`that was examined and looked at and considered by
`
`the examiner in the prosecution?
`
` MR. BARROW: Objection, relevance.
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` A Well, normally I would do that of course.
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`I just don't recall having done it in this case. As
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`I recall, we were on a very short schedule and I may
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`have done that, I just don't plain remember.
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` Q Would you have any notes if you had done
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`that?
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` MR. BARROW: I would caution the witness
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`not to reveal the substance of any privileged
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`communication.
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`IPR2015-00887
`Exhibit 2007
`Page 26 of 374
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`
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` Q Sir, if you have notes, but not the
`
`contents of those notes.
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` A Well, I have notes of course, but as you
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`say or as Mr. Barrow said, I can't reveal what they
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`are.
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` Q When was the last time you reviewed those
`
`notes?
`
` A Early this year probably.
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` Q Did you review them in preparation for
`
`this deposition?
`
` A Actually not. I forgot I had them.
`
` Q Okay. Doctor, you looked at the petition
`
`yesterday as well; is that right?
`
` A Yes.
`
` Q Did you review it in some detail, do you
`
`think?
`
` A No.
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` Q How would you describe your review of the
`
`petition?
`
` A We had quite a few documents to go through
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`and there were certain portions of it that were more
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`important than others, and I remember that we looked
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`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2007
`Page 27 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`at those, discussed them, and the same with my
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`declaration, we only had one day.
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` Q Would you say that you reviewed your
`
`declaration in detail yesterday?
`
` A That I looked at more carefully, yes.
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` Q In reviewing your declaration, did you
`
`spot any errors?
`
` A Yes.
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` Q Would you describe those errors for me.
`
` A I forget exactly where but figure 2 is
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`referenced and said that it's shown below and I
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`don't know what happened, it was in there
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`originally. I think I wanted to annotate it so I
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`took it out and then forgot to put it in.
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` Q Is there anything else that you noticed?
`
` A No, nothing that I would call an error or
`
`misrepresentation or anything like that.
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` Q So that was the only one that figure 2 was
`
`missing?
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` A Yes, but I know it's in the patent so it's
`
`not an entirely lost cause.
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` Q Was this a figure 2 from the '843 patent?
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`IPR2015-00887
`Exhibit 2007
`Page 28 of 374
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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` A Yes.
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` Q So as you were going through your
`
`declaration, aside from figure 2 that was missing,
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`did you see anything else that you would change if
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`you could go back and do it over?
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` A No, I don't think so.
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` Q So your declaration stands with that?
`
` A Yes.
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` Q Dr. Zech, let's talk about LCD technology
`
`in general.
`
` A Sure.
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` Q When did you first hear the term
`
`overdrive, do you recall?
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` A Sometime in the '90s --
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` Q 1990s?
`
` A -- at a conference.
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` Q If you weren't finished, I apologize.
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` A No, I'm through. I have a good memory but
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`20 years later or so it's not as good as I would
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`like it to be.
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` Q When you heard about overdrive in the
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`1990s, do you remember the context in which it was
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`IPR2015-00887
`Exhibit 2007
`Page 29 of 374
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`
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`Deposition of Richard Zech, Ph.D.
`Conducted on November 13, 2015
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`being discussed?
`
` A Yes, I think I can say that with
`
`certainty. The LCD products were not introduced
`
`until about 1985. They weren't very good. In the
`
`mid '90s they still weren't very good. Now if you
`
`understand the physics, and I'm not going to put you
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`on the spot here, but to those who understand the
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`physics of the device, they know that you can build
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`a good panel and it is what it is. If you want to
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`improve its performance, you have to do things in
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`the electronics and you got to look at these as two
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`separate entities, LCD panel, electronics.
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` Now we are in a situation here where we
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`have a device whose inherent characteristic is what
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`we call RC, resistance capacitance. It's
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`essentially one big capacitor divided into M by N
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`pixels. Now RC circuits don't like to be kicked
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`around. You try to push them, they push back at
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`you. You turn them off. They are still charged,
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`drained from the capacitor part of it.
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` So
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