`-----------------------------------
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-----------------------------------
`VIZIO, INC.,
`Petitioner,
`v.
`NICHIA CORPORATION,
`Patent Owner.
`-----------------------------------
`Case No. IPR2018-00386
`Patent 9,490,411
`DEPOSITION OF STANLEY R. SHANFIELD, Ph.D.
`East Palo Alto, California
`Wednesday, December 19, 2018
`9:10 a.m.
`
`Job No.: 221516
`Pages: 1 - 101
`Reported By: Charlotte Lacey, RPR, CSR No. 14224
`
`NICHIA EXHIBIT 2021
`Vizio, Inc. v. Nichia Corp.
`Case IPR2018-00386
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`2
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` DEPOSITION OF STANLEY R. SHANFIELD, Ph.D., held at
`the offices of ROPES & GRAY LLP, 1900 University Avenue,
`6th Floor, East Palo Alto, California
`
` Pursuant to notice, before Charlotte Lacey,
`Certified Shorthand Reporter, in and for the State of
`California.
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`3
`
` A P P E A R A N C E S
`ON BEHALF OF PETITIONER VIZIO, INC.:
` GABRIELLE E. HIGGINS, ESQUIRE
` CHRISTOPHER M. BONNY, ESQUIRE
` JAMES F. MACK, ESQUIRE
` ROPES & GRAY LLP
` 1900 University Avenue, 6th Floor
` East Palo Alto, California 94303
` (650) 617-4000
`
`ON BEHALF OF PATENT OWNER NICHIA CORPORATION:
` MICHAEL H. JONES, ESQUIRE
` MARTIN M. ZOLTICK, ESQUIRE
` ROTHWELL, FIGG, ERNST & MANBECK, PC
` 607 14th Street, Northwest, Suite 800
` Washington, D.C. 20005
` (202) 7883-6040
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`Conducted on December 19, 2018
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`4
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` I N D E X
` WITNESS PAGE
` STANLEY R. SHANFIELD, Ph.D.
` Examination by Mr. Jones 5
`
` I N D E X O F E X H I B I T S
` EXHIBITS DESCRIPTION PAGE
`Exhibit S1 Blowup of figure 1 16
`Exhibit S2 Blowup of figure 1 19
`Exhibit S3 Annotated version of figure 1 31
`Exhibit S4 Annotated version of figure 1 35
`Exhibit S5 Three-dimensional block 44
`Exhibit S6 LED outer side surface, Upper 50
` surface of exposed lead
`Exhibit S7 Illustration in figure 1 62
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`5
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` P R O C E E D I N G S
` STANLEY R. SHANFIELD, Ph.D.,
`the witness herein, having been first duly sworn, was
`examined and testified as follows:
` EXAMINATION
`BY MR. JONES:
` Q Good morning, Dr. Shanfield.
` A Good morning.
` Q My name is Michael Jones. I'm from the law
`firm of Rothwell Figg. And I'm joined by Marty Zoltick,
`also of Rothwell Figg.
` Can you please state your full name for the
`record.
` A Stanley R. Shanfield.
` Q Okay. And where do you work?
` A Work at Draper Laboratories.
` Q And what's your position at Draper
`Laboratories?
` A I'm a distinguished member of technical staff.
` Q And how long have you been a distinguished
`member of technical staff?
` A I don't exactly remember when I was awarded
`that, but I started in 2003.
` Q Started at Draper in 2003?
` A Yes, right.
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`6
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` Q Okay. And where were you before Draper?
` A I was at a start-up company that I helped
`found, AXSUN Technologies.
` Q Okay. And you've been deposed before, yes?
` A Yes.
` Q And so, then, you understand how a deposition
`works?
` A Pretty well, yes.
` Q Okay. Well, then, I'll remind you of a couple
`of the ground rules. How does that sound?
` A Sure.
` Q So I'm going to ask you a series of questions,
`okay?
` A Uh-huh.
` Q And if you don't understand the question, I'd
`ask that you not answer it. Just let me know, and I'll
`clarify or rephrase it.
` A Okay.
` Q And if you answer a question, I'll
`understand -- I'll assume that you understood.
` A All right.
` Q And anytime you need a break, just ask, and
`when we get to a good stopping point, we'll take one.
` A Great. Good.
` Q And you understand that you are under oath?
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`7
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` A Yes.
` Q And you are -- you understand that you are
`here pursuant to a deposition notice to answer questions
`relating to an IPR?
` A Yes.
` Q Okay. And I think the first one we're
`covering is IPR2018-00386, which is about U.S.
`Patent 9,490,411.
` A Yes.
` Q And if I refer to the '411 patent, you'll know
`what I'm talking about?
` A Yes, I will.
` Q Okay. I see that you have a number of papers
`in front of you. Could you tell me what you have?
` A So I have my declaration on the '411 patent,
`that is "Declaration of Dr. Stanley Shanfield in Support
`of Petitioner's Reply to Patent Owner's Response." It's
`Exhibit 1017 of -- Exhibit 1017 on the '071 patent. And
`then in the other two tabs are my old declaration, which
`is Exhibit 1003.
` Q Okay. And there's --
` A And then I have the patents, '411 and
`'071 patent.
` Q Okay. And are those clean copies, or are --
` A Yes.
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`8
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` Q -- they marked up in any way?
` A Not marked in any way.
` Q Okay. So since we're talking about the
`'411 patent, if I ask you about your declaration or the
`patent during this part of the proceeding, you
`understand I'm referring to 1017 with respect to the
`'411 and the '411 patent?
` A Yes, I do.
` MS. HIGGINS: Okay. And, Counsel, just for
`the record, Dr. Shanfield is here today with respect to
`both of the deposition notices that you served, so the
`deposition notice in the -- both the '386 proceeding and
`the '437 proceeding.
` MR. JONES: Yep, so I -- we hope to proceed as
`we have in the past instances in which we do one IPR,
`stop, start a new record, and do the next IPR. Does
`that work for you?
` MS. HIGGINS: Are you taking both of those?
` MR. JONES: Sorry. One -- yes.
` MS. HIGGINS: You're taking both depositions
`today?
` MR. JONES: Uh-huh.
` MS. HIGGINS: Fine.
` MR. ZOLTICK: Unless something happens.
` MR. JONES: Yeah, that's the plan. Yes.
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`9
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` MS. HIGGINS: The answer is yes. Thank you.
` MR. JONES: All right. So that works for you?
` MS. HIGGINS: Yes.
` MR. JONES: Okay.
`BY MR. JONES:
` Q So did you prepare for today's deposition?
` A Yes, I did.
` Q And what did you do to prepare?
` MS. HIGGINS: And you can answer the question.
`Just don't reveal any communications that you had with
`counsel.
` A I reviewed my declarations. I -- where I had
`questions, I talked to counsel and worked with counsel
`to make sure I understood what I was reading and what
`I -- what the legal issues were.
` Q Okay. And who did you meet with?
` A Gabby and -- I mean, the people in this room.
` Q Okay. Did you meet with anyone in preparation
`for your deposition outside of this room?
` A No.
` Q Okay. And about how long did you spend
`preparing for today's deposition?
` A Might be approximately six to eight hours.
` Q Okay. When did you arrive in California?
` A On Sunday, but I went to see relatives in
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`10
`
`Berkeley. So I didn't actually meet with attorneys
`initially.
` Q Okay. I understand that you have the -- the
`'411 patent in front of you; is that correct?
` A Yes.
` Q Okay. Does anybody else need a copy of the
`patent?
` Okay. So this is -- the '411 patent was
`previously marked as 1001, correct?
` A Yes.
` Q Okay. Can you please look at column 19,
`lines 45 to 48. And do you see there's a clause of
`claim 1 that starts with "Wherein"?
` A Yes.
` Q Can you please read that to yourself.
` A Okay.
` Q Have you read that clause?
` A Yes, I have.
` Q Okay. And that clause reads "Wherein both a
`part of the metal part and a part of the resin part are
`disposed in a region below an upper surface of the metal
`part on four outer lateral surfaces of the resin
`package"; is that correct?
` A Yes, it is.
` Q Okay. And I'd like to point your attention to
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`11
`
`the middle part of that clause, which reads, "Disposed
`in a region below an upper surface of the metal part."
`Do you see that?
` A Yes.
` Q So when you provided your opinions regarding
`claim 1 for this IPR, including in the declaration 1017
`in front of you, what meaning did you use for the phrase
`"disposed in a region below an upper surface of the
`metal part"?
` A I took the claim language in its entirety. So
`I used its plain meaning in understanding what that
`meant.
` Q And what is that plain meaning?
` A So I have examples in my dec which probably
`explain it most clearly. If you start with page 7, I
`talk about figure 1, "Corresponding to the first
`embodiment," and that discloses the -- and shown in
`blue -- a part of the metal part shown in blue, I mean,
`and a part of the resin part that's shown in green are
`disposed in a region below an upper surface of the metal
`part, which I've outlined in blue, on four outer lateral
`surfaces, and I've outlined all of that in red.
` Q Okay. So you -- your -- I think what you're
`telling me is that your -- your understanding is
`informed by what's shown here in figure 1, right?
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`12
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` A Yeah. I want to point out also, there's no
`portion of resin part 25 in figure 1 -- I'm showing now
`at the top of page 8 -- located directly under metal on
`four outer lateral surfaces.
` Q Okay. I think I understand your opinion with
`respect to that. I'm asking you a slightly different
`question.
` Earlier you told me that you applied the plain
`meaning to this phrase, correct?
` A That's correct.
` Q Can you articulate what the plain meaning of
`"below" is?
` A Another way of explaining "below" is "at a
`lower level than."
` Q Okay.
` A I think the example I'm showing here, though,
`shows it clearly.
` Q Okay. So is it your opinion that the phrase
`"disposed in a region below an upper surface of the
`metal part" means disposed in a region at a lower level
`than an upper surface of the metal part?
` A On the four outer lateral surfaces of the
`resin package.
` Q Yes. So I'll re-ask my question.
` Is it your understanding that this phrase
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`13
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`means disposed in a region at a lower level than an
`upper surface of the metal part on four outer lateral
`surfaces of the resin package?
` MS. HIGGINS: Object to form.
` A So I used the plain meaning. And that was a
`way I understood -- or that describes the way I
`understood this. I didn't put any construction on it.
`It's simply the way I understood the phrase.
` Q So I think the answer to my -- my question
`was -- was yes, but I'll re-ask it.
` So the way you understood the phrase is
`disposed in a region at a lower level than an upper
`surface of the metal part on four outer lateral surfaces
`of the resin package?
` MS. HIGGINS: Object to form.
` Q Is that correct?
` MS. HIGGINS: Asked and answered.
` A I think I've answered your question.
` Q And is the answer yes?
` A Well, you didn't -- I took the phrase in its
`entirety "wherein both a part of the metal part and a
`part of the resin part are disposed in a region below an
`upper surface of the metal part on four outer lateral
`surfaces of the resin package."
` And as I've interpreted it and shown in
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`14
`
`figure 1, I'm showing in blue, I'm showing a line that
`is the metal part and -- a part of the metal part. And
`a part of the resin part I'm showing in green in
`figure 1. And they are disposed in a region below an
`upper surface of the metal part. And the line in blue
`represents where that upper surface is on the four outer
`lateral surfaces. The outer lateral surfaces are
`outlined in red in figure 1, page 8 in my declaration.
`And the -- the blue line indicates where I'm talking
`about what's below that line.
` Q Okay. So it -- it sounds like you felt that
`my question was incomplete 'cause it wasn't all the --
`the language of that clause. So I'm going to ask it
`slightly differently and include the full -- the full
`clause, because I think that's what you're asking. So
`here we go.
` When you provided your opinion, you understood
`the -- this phrase to mean wherein both a part of the
`metal part and a part of the resin part are disposed at
`a lower level than an upper surface of the metal part on
`four outer lateral surfaces of the resin package,
`correct?
` MS. HIGGINS: Object to form.
` A No, that's not what I said. First of all, you
`left out "in a region."
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`15
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` Q All right. Let's try it again. When you
`apply -- when you provided your opinion with respect to
`the '411 patent in claim 1, the meaning you gave this
`clause was wherein both a part of the metal part and a
`part of the resin part are disposed in a region at a
`lower level than an upper surface of the metal part on
`four outer lateral surfaces of the resin package,
`correct?
` MS. HIGGINS: Same objection.
` A That was how I took the plain meaning of this
`claim element.
` Q Okay. So I'm going to ask you questions today
`about your construction and what the patent means. So
`when I ask about the meaning you applied, that's the
`meaning I'm going to be referring to. Do you
`understand?
` A Yes.
` Q Okay. So you referenced an annotated figure
`you have on -- on page 8, right?
` A Yes, that's correct.
` Q And that's an annotated version of figure 1,
`correct?
` A Yes, that's correct.
` Q And you have shown the metal part at the outer
`surfaces in light blue, correct?
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`16
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` A I've shown a part of the metal part in light
`blue, yes.
` Q And the part of the metal part that is exposed
`at the outer lateral surfaces is shown in light blue,
`correct?
` A Right.
` MS. HIGGINS: Object to form.
` MR. JONES: Okay. So I'm going to mark as
`Exhibit S1 a blowup of figure 1 with the exposed
`portions of the metal part at the outer lateral surface
`shown in light blue.
` (Deposition Exhibit S1 was marked for
`identification.)
` MS. HIGGINS: So, Counsel, I'm just -- you --
`have you changed the color? Because he's calling it
`blue. I just want to understand. Is this something
`that you created?
` MR. JONES: Yes.
` Q So this is -- this is a -- a direct copy of
`figure 1 from the '411 patent. And I've added light
`blue coloring to the metal parts at the outer lateral
`surfaces. Do you see that, Dr. Shanfield?
` A Yes.
` Q Okay. I'm handing you a red pen. Okay? Can
`you please use the red pen to mark the up -- the upper
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`17
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`surface of the metal part at the four outer lateral
`surfaces of the resin package.
` MS. HIGGINS: Object to form.
` A I've already drawn that. If you look at the
`top of page 8, it isn't blue; it's kind of purplish.
`But I've put an arrow and pointed to a part of the metal
`part and then another arrow for a part of the resin
`part. So I see no need to reproduce the drawing I've
`put in my declaration at page 8.
` Q I'm asking you to, so, please, make the
`marking I asked for.
` MS. HIGGINS: Same objection.
` A I'm going to end up reproducing this drawing.
` Q Okay. I'm asking you to reproduce the drawing
`in its entirety. I'm asking you to mark only with the
`red pen the upper surface of the metal part at the four
`outer lateral surfaces of the resin package.
` MS. HIGGINS: Object to form.
` A The upper surface of the metal part.
` Q Yeah.
` A Didn't -- did you say "a part of the metal
`part" earlier? No. All right. You're asking me to
`redraw the blue line that I've put in -- I've annotated
`figure 1 on page 8.
` Q I am asking you to draw with the red pen the
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`18
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`upper surface of the metal part at the outer lateral
`surfaces shown in Exhibit S1.
` MS. HIGGINS: Object to form.
` A In my drawing, what I've indicated and what
`I'm going to indicate here is the upper surface of the
`metal part on the outer lateral surface -- four outer
`lateral surfaces. Obviously, I can't draw on all four
`of them, so I'm going to draw on two, but with the
`understanding that this is a symmetric package.
` Q Okay.
` A Now, I'm not going to draw as well as I did in
`annotating figure 1 on page 8. But essentially
`reproducing -- exactly reproducing what I drew.
` Q Okay.
` A As annotation in figure 1.
` Q Okay. May I see your annotation? Thank you.
` So, to be clear, you've drawn a red line not
`only on top of the blue parts but between the blue
`parts, correct?
` MS. HIGGINS: Object to form.
` A So as I explained in page 7 in figure 1 in my
`annotation, which I'm attempting to reproduce here, I've
`disclosed in that annotation the complete -- my
`understanding of the entire claim element disclosing a
`part of the metal part which is blue and a part of the
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`19
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`resin part which is green disposed in a region below on
`upper surface of the metal part. And the region below
`an upper surface, I've outlined in blue so that I can
`indicate what's below an upper surface on four outer
`lateral surfaces. The lateral surfaces I've outlined in
`red, and -- and I believe this is a really clear drawing
`of my understanding.
` Q Okay. So I -- I asked you something
`different. I did not ask you to reproduce your drawing
`from your --
` A That's what I'm doing.
` Q Okay. Well --
` MS. HIGGINS: Object to form.
` Q You have to answer my questions. Do you
`understand? So I'm going to ask --
` MS. HIGGINS: Object to form.
` MR. JONES: We're going to -- we're going to
`get a new exhibit. We're going to call it S2.
` (Deposition Exhibit S2 was marked for
`identification.)
` Q And I'm going to ask you to do something
`specific, and I'd ask that you please do it.
` MR. JONES: So this is the -- the same
`drawing, Counsel, marked as Exhibit S2.
` Q We're going to try again. You can put S1
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`20
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`aside.
` A Can I make it clear that I -- this is a
`reproduction by labeling it?
` MS. HIGGINS: You can go ahead and do whatever
`you want that you need to do, Dr. Shanfield.
` Q You can hold on to that. So I've put in front
`of you another copy of the same image now marked S2. Do
`you see that?
` A Yes.
` Q Okay. So -- and, please, confirm you
`understand. I am not asking you to reproduce the
`drawing shown on page 8 of your declaration. Do you
`understand?
` MS. HIGGINS: Object to form.
` A I'll understand further when you tell me what
`you are asking me to do.
` Q Okay. So let's -- let's take it piece by
`piece. Do you understand that I am not asking you to
`reproduce the figure shown on page 8 of your
`declaration?
` A I understand that you're asking me that, yes.
` Q Okay. So I am asking you to, please, with the
`red pen, identify the upper surfaces of the metal part
`at the outer lateral surfaces as shown in Exhibit S2.
` MS. HIGGINS: Object to form.
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`21
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` A The drawing that I show in page 8 is
`addressing the claim language precisely, in my opinion.
`What you are asking me to do is something outside of
`what the claim language is addressing, which is a part
`of the metal part and a part of the resin part
`disposed -- are disposed in a region below an upper
`surface of the metal part on four outer lateral surfaces
`of the resin package. And I -- and you're asking me to
`opine on something isn't described or discussed in the
`patent, and that is -- it's simply not in the context of
`the patent something that has been -- if -- maybe you
`can show me where there's a -- a reason to be specifying
`what you asked for. I'd be interested in seeing that,
`'cause what the language of the claim is asking for is
`what is the part of the metal part and the part of the
`resin part disposed in a region below an upper surface
`of the metal part on four outer lateral surfaces of the
`resin package.
` So the claim language is requiring me to
`understand what that means. And I've indicated it here
`in my drawing on page 8.
` Q And as -- and, as we discussed, I'm not asking
`you to -- to recreate your drawing from page 8.
` A I understand. But you're asking me to
`recreate something that's not -- something I haven't
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`22
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`opined on.
` Q I know you -- you want a reason, but that's
`not exactly how this works. I'm asking you one simple
`question. Okay? And if you can't do it, just state for
`the record you can't do it. Please identify with the
`red pen the upper surface of the metal part at the outer
`lateral surfaces shown in Exhibit S2.
` MS. HIGGINS: Object to form.
` Q And, to be clear, I'm not asking you to
`recreate the image of page 8. I'm not asking you to
`identify regions below any surface. I'm starting with
`an initial question which is "please identify with the
`red pen the upper surface of the metal part at the outer
`lateral surfaces shown in Exhibit S2."
` MS. HIGGINS: Object to form.
` A So what I've opined on -- and I'll repeat
`myself -- in page 8 is what I described earlier, that
`I've included a blue line, and that blue line is where
`it discloses a part of the metal part and a part of the
`resin part. And the metal part's shown in blue, the
`resin part's shown in green, are disposed in a region
`below an upper surface of the metal part on four outer
`lateral surfaces.
` So I've outlined in blue an upper surface of
`the metal part on four outer lateral surfaces. That is
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`23
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`what I've opined on and what is, in my view, necessary
`to -- for my understanding of this phrase -- of this
`claim element.
` You're asking me to draw some hypothetical
`surface. And the patent is not -- it -- maybe you can
`show me where there is a requirement for or an
`understanding of that hypothetical surface. And I have
`not opined on it, and I believe that what I've shown in
`figure 1 annotated on page 8 is exactly what is required
`and what is referred to in this element.
` Q Okay. Move -- move to strike, nonresponsive.
` Are you able to identify with the red pen the
`upper surfaces of the metal part at the outer lateral
`surfaces shown in Exhibit S2?
` MS. HIGGINS: Object to form.
` A You are asking me to opine on something I
`haven't opined on, and I'm simply not comfortable
`opining on it.
` Q So the answer is, no, you are not able to?
` A No, I did not --
` MS. HIGGINS: Object to form.
` A I did not answer it that way. I said I am not
`comfortable opining on this hypothetical that you seem
`to be describing, and I believe what I've given in
`figure 1 annotated on page 8 is a complete explanation
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`24
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`of how I understand the language in the claim.
` So asking for some geometric entity that
`you're trying to describe that's outside what I've
`opined is not something I'm comfortable doing.
` Q Okay. So I'm not asking what you're
`comfortable doing. I'm asking what you are able to do.
`Not "willing." What you are able to do.
` Are you able to identify with the red pen the
`upper surfaces of the metal part at the outer lateral
`surfaces shown in Exhibit S2?
` MS. HIGGINS: Object to form.
` A I've identified with the thick blue line on
`page 8, annotated figure 1, an upper surface of the
`metal part on four outer lateral surfaces. And I've
`outlined that in blue. But, yet, when I reproduced it,
`you didn't seem to accept that as sufficient.
` So you're asking for something beyond what
`I've opined on. And since I'm not fully clear -- I
`don't understand what you're asking for, first of all.
`I -- I'm -- and I'm not comfortable opining on it by
`trying to guess what you mean. And, therefore, I'm just
`simply not comfortable doing it here.
` Q So you will not, as you sit here today,
`identify with the red pen the upper surfaces of the
`metal part at the outer lateral surfaces shown in
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`25
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`Exhibit S2; is that correct?
` MS. HIGGINS: Object to form, mischaracterizes
`the witness's testimony.
` A So you're mischaracterizing what I've said.
`I've drawn exactly what I believe you are -- the point
`is of an upper surface of the metal part on four outer
`lateral surfaces, and that's in the thick blue line on
`the annotated figure 1 on page 8. I've drawn that for
`you.
` And you seem to be asking me for something in
`addition to that. And I'm not comfortable trying to
`figure out what you mean. And -- I feel this figure and
`the thick blue line is more than sufficient to indicate
`what I mean when I interpreted this claim element.
` MR. JONES: We're going to take a break.
` MS. HIGGINS: Okay.
` (A recess ensued from 9:42 a.m. to 9:47 a.m.)
` MR. JONES: All right. Let's go back on the
`record. And I'd like to ask the court reporter to
`please mark the previous exchange starting at 17:25 in
`case we need to find that later.
` Q Okay. I'm going to try this again. Please
`turn to column 19 of the '411 patent at line 46.
` A Yes.
` Q So one of the features of claim 1 is an upper
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`26
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`surface of the metal part on four outer lateral surfaces
`of the resin package. Do you see that?
` A I don't know what you mean by a feature. I
`mean, I took the claim element in its entirety, and I'm
`not sure I can divide it into features --
` Q Well, a part of that claim --
` A -- like the way you're talking about.
` Q Well, a part of that claim element is an upper
`surface of the metal part on four outer lateral surfaces
`of the resin package, correct?
` A Yes.
` Q Okay. So with that -- that understanding of
`an upper surface of the metal part, please turn back to
`Exhibit S2, and I'll ask are you able to, using the red
`pen, identify the upper surface of the metal part at the
`outer lateral surfaces shown in Exhibit S2?
` A I've explained in my declaration I have
`already indicated with the thick blue line on the
`annotated figure 1 drawing in the -- the top of the
`page, page 8, the upper surface of the metal part. As I
`said, it's outlined in blue -- so I'm reading from my
`dec -- on four outer lateral surfaces, and I've outlined
`in red the outer lateral surfaces as well.
` Q Did you prepare the -- the figure shown on
`page 8 of your dec?
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`Transcript of Stanley R. Shanfield, Ph.D.
`Conducted on December 19, 2018
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`27
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` A I am responsible for everything in my dec and
`have made sure and can tell you now it reflects my
`opinion exactly.
` Q So would it be fair to say that, when you
`prepared your declaration, you were able to identify the
`upper surface of the metal part at the outer lateral
`surfaces?
` A On four outer lateral surfaces, so yes.
` If you look at figure 1 annotation, the thick
`blue line, as I've indicated, it's -- and I use it to
`indicate a region below an upper surface of the metal
`part on four outer lateral s