THOMAS L. CREDELLE
`
`Page 1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---o0o---
`
`NICHIA CORPORATION, )
` Petitioner, )
` vs. ) No. IPR2018-00966
`DOCUMENT SECURITY SYSTEMS, )
`INC., )
` Patent Owner. )
`______________________________)
`
` VIDEOTAPED DEPOSITION OF THOMAS L. CREDELLE
` WEDNESDAY, APRIL 17, 2019
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`Nichia Exhibit 1017
`Page 1
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`
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`Page 1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---o0o---
`
`NICHIA CORPORATION, )
` Petitioner, )
` vs. ) No. IPR2018-00966
`DOCUMENT SECURITY SYSTEMS, )
`INC., )
` Patent Owner. )
`______________________________)
`
` VIDEOTAPED DEPOSITION OF THOMAS L. CREDELLE
` WEDNESDAY, APRIL 17, 2019
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`Nichia Exhibit 1017
`Page 1
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`
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`THOMAS L. CREDELLE
`
`Page 2
`
` Deposition of THOMAS L. CREDELLE, taken on behalf
`of Petitioner, at SHEARMAN & STERLING, 1460 El Camino
`Real, 2nd Floor, Menlo Park, California, commencing at
`9:04 a.m., Wednesday, April 17, 2019, before Kelli
`Combs, CSR No. 7705.
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`1234567
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`THOMAS L. CREDELLE
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`Page 3
`
`APPEARANCE OF COUNSEL:
`
`FOR PETITIONER:
` SHEARMAN & STERLING
` BY: PATRICK R. COLSHER, ESQ.
` 599 Lexington Avenue
` New York, New York 10022
` 212.848.7708
` patrick.colsher@shearman.com
`
`FOR PATENT OWNER:
` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
` BY: WAYNE HELGE, ESQ.
` 8300 Greensboro Drive, Suite 500
` McLean, Virginia 22102
` whelge@dbjg.com
`
`Also present:
`Alfredo Domador, videographer
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`THOMAS L. CREDELLE
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`Page 4
`
` I N D E X
`April 17, 2019
`
`THOMAS L. CREDELLE
`EXAMINATION PAGE
`
` (BY MR. COLSHER) 8, 182
` (BY MR. HELGE) 179
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`THOMAS L. CREDELLE
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`Page 5
`
` I N D E X
` EXHIBITS FOR IDENTIFICATION
`PETITIONER'S PAGE
`Exhibit 1018 Blowup of annotation from 82
` page 10 of Declaration of
` Thomas L. Credelle
`Exhibit 1019 Blowup of annotation from 95
` page 10 of Declaration of
` Thomas L. Credelle with
` highlighting
`
` PREVIOUSLY MARKED EXHIBITS
` EXHIBIT PAGE
` Nichia 1001 31
` Nichia 1004 53
` Nichia 1006 72
` Nichia 1007 40
` Patent Owner's 2009 17
` Patent Owner's 2010 17
`
` * * * *
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`THOMAS L. CREDELLE
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`Page 6
` Wednesday, April 17, 2019; Menlo Park, California
` 9:04 a.m.
` ---o0o---
`
` THE VIDEOGRAPHER: Good morning. We're
`going on the record at 9:04 a.m. on April 17th,
`2019. Please note that the microphones are
`sensitive and may pick up whispering, private
`conversations, and cellular interference. Please
`turn off all cell phones or place them away from the
`microphones, as they can interfere with the
`deposition audio. Audio and video recording will
`continue to take place unless all parties agree to
`go off the record.
` This is Media Unit 1 in the video-recorded
`deposition of Thomas L. Credelle in the matter of
`Nichia Corporation versus Document Security Systems,
`Incorporated, filed in the United States Patent and
`Trademark Office before the Patent Trial and Appeal
`Board.
` This deposition is being held at Shearman
`& Sterling, located at 1460 El Camino Real, Second
`Floor, Menlo Park, California 94025.
` My name is Alfredo Domador from the firm
`Veritext, and I am the videographer. The court
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`Nichia Exhibit 1017
`Page 6
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`THOMAS L. CREDELLE
`
`Page 7
`reporter is Kelli Combs from the firm Veritext. I
`am not related to any party in this action, nor am I
`financially interested in the outcome.
` Counsel and all present in the room and
`everyone attending remotely will now state their
`appearances and affiliations for the record. If
`there are any objections to proceeding, please state
`them at the time of your appearance, beginning with
`the noticing attorney.
` MR. COLSHER: Patrick Colsher with
`Shearman & Sterling for the petitioner, Nichia
`Corporation.
` MR. HELGE: Wayne Helge from Davidson
`Berquist Jackson & Gowdey for the Patent Owner,
`Document Security Systems, and defending the
`witness, Tom Credelle.
` THE WITNESS: And I'm Tom Credelle.
` THE VIDEOGRAPHER: Thank you, Counsel.
` Will the reporter please swear in the
`witness.
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`Nichia Exhibit 1017
`Page 7
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`
`
`THOMAS L. CREDELLE
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`Page 8
`
` THOMAS L. CREDELLE,
` after having been duly sworn, testified as follows:
` ---o0o---
`
` EXAMINATION
`BY MR. COLSHER:
` Q Good morning, Mr. Credelle.
` A Good morning.
` Q Is there any reason you cannot testify
`truthfully today?
` A No.
` Q Are you on any medication?
` A No.
` Q Get a good night's sleep?
` A Yes.
` Q Have you been deposed before?
` A Yes.
` Q So I take it you're generally familiar
`with how this works.
` A I am.
` Q About how many times have you been
`deposed?
` A Probably more than 10.
` Q More than 10.
` Have any of them been in the context of
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`THOMAS L. CREDELLE
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`Page 9
`
`these inter partes reviews?
` A Yes.
` Q About how many of those?
` A I don't recall exactly, but probably four
`or five at least.
` Q And do you recall the last time?
` A The last deposition or --
` Q Yeah.
` A -- last IPR?
` Q The last deposition.
` A Last deposition was about -- in November.
` Q And what about the last IPR deposition?
` A I don't recall exactly. Maybe a couple
`years ago.
` Q Okay.
` So please ask if you don't understand a
`question or if you'd like me to rephrase it. If you
`don't ask, I'll assume that you understand.
` Is that -- is that okay?
` A Yes.
` Q Okay.
` And you understand you're here to provide
`testimony for two IPRs today?
` A That's correct.
` Q The first one is IPR Case Number IPR
`
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`Page 9
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`THOMAS L. CREDELLE
`
`Page 10
`2018-1165. That's regarding U.S. Patent No.
`7,524,087.
` Does that sound -- '087 patent?
` A The '087. That's one of them.
` Q All right.
` And the other one is IPR Case Number IPR
`2018-0966, and that's involving Patent 7,625,297?
` A '297, yes, that's --
` Q Okay.
` A -- correct.
` Q And you submitted a declaration for the
`IPR involving the '087 patent, correct?
` A I did submit a declaration.
` Q Okay.
` And you also submitted a declaration in
`the IPR involving the '297 patent, correct?
` A That is correct.
` Q I'm going to try to keep these -- because
`we have a single record, but we have two IPRs, we'll
`try to keep these separate. But, you know, for some
`of this, I'll -- the likelihood is that it will
`apply to -- apply to both --
` A Okay.
` Q -- both IPRs, at least in the context of
`the background.
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`Page 10
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`
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`THOMAS L. CREDELLE
`
`Page 11
` In the '087 declaration, the materials
`that you reviewed, are those the ones that are cited
`in the declaration?
` A I did review those documents, that's
`correct --
` Q Did --
` A -- that were cited.
` Q Do you recall if you reviewed anything
`else other than those documents?
` A No. I think I read the patent and the --
`well, you have the list. The patent, the
`declaration of Dr. Shealy, I believe. Well,
`whatever is in the list, that's what I read. I
`didn't memorize it.
` Q I'm not trying to make this a memory test.
` And the same question for the '297 patent;
`the materials that you reviewed are the ones that
`you cited in your declaration?
` A Yes, the ones that are cited. There is no
`list, but the ones that are cited.
` Q What did you do to prepare for your
`deposition today?
` A I wrote these declarations a while ago, so
`I reread the declarations, I reread the patents, and
`I looked at the content of the various patents and
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`THOMAS L. CREDELLE
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`Page 12
`what I said. That's the main thing I did to refresh
`my memory.
` Q And about when did you rereview the --
`your declaration in the '087 patent, if you recall?
` A I guess I did a little bit on Sunday and
`then on the plane ride down.
` Q And what about for the '297 patent; do you
`recall when you reviewed it?
` A Around the same -- same time.
` Q About how long did you spend preparing for
`this deposition?
` A Maybe totally, including some discussions
`with my attorney, four or five hours perhaps.
` Q And are you comfortable testifying today
`about the opinions you provided in your
`declarations?
` A I'm comfortable testifying about those
`opinions, yes.
` Q Did anything you reviewed in preparation
`for your deposition today refresh your recollection?
` A I'm sorry. Did -- say again.
` Q Did anything you reviewed in preparation
`for your deposition today refresh your recollection?
` MR. HELGE: I'm going to object to form of
`that question.
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`THOMAS L. CREDELLE
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`Page 13
` THE WITNESS: Yeah, I -- I don't -- I --
`what I read refreshed my knowledge about the case,
`if that's what you asked.
`BY MR. COLSHER:
` Q And earlier, you testified that you wrote
`your declarations for these IPRs?
` A Yes.
` Q Did you write them yourself?
` A I drafted and wrote -- and prepared them
`in collaboration with the attorney firm, but they
`were my word- -- my thoughts.
` Q Were you given --
` Do you recall if you were given any drafts
`of the Patent Owner replies while you were writing
`your declarations?
` MR. HELGE: Object to form.
` THE WITNESS: When -- in writing my
`declaration, I wrote my declaration based on the --
`what I was asked to opine upon, and I did review
`previous documents, like the Patent Owner response
`and the petition, in preparation for writing my
`declaration.
`BY MR. COLSHER:
` Q Other than the opinions in your
`declaration, were you asked to opine on any
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`THOMAS L. CREDELLE
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`Page 14
`
`additional issues?
` A No.
` MR. HELGE: Object to form.
`BY MR. COLSHER:
` Q Are you being compensated for your time in
`connection with these proceedings?
` A Yes.
` Q Is your compensation the same for both
`proceedings?
` A Both IPRs?
` Q Yes, both IPRs.
` A Yes.
` Q How are you being compensated?
` A By check.
` Q Are you being paid hourly?
` A Hourly.
` Q What is that rate?
` A Is that relevant?
` Q It can be.
` A 400 an hour.
` Q Is your compensation in any way tied to
`the testimony you provide?
` A No.
` Q Is your compensation in any way tied to
`the outcome of these proceedings?
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`THOMAS L. CREDELLE
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`Page 15
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` A Absolutely not.
` Q Other than these proceedings, these two
`IPRs that we're talking about, have you ever done
`any work for the Patent Owner, Document Security
`Systems?
` A Not -- I've reviewed other IPRs that they
`have underway, but I've only done work on these two.
` Q But they were in connection with -- but --
`strike that.
` The other IPRs you referred to, they are
`also related to LEDs?
` A Yes.
` Q Other than these proceedings, have you
`ever done any work for companies related to the
`Patent Owner, Document Security Systems, that you
`know of?
` MR. HELGE: Object to form.
` THE WITNESS: Not that I know of.
`BY MR. COLSHER:
` Q Other than these two proceedings, have you
`ever done any work for any prior owner of the '087
`patent?
` A I don't recall the previous owners, so
`I --
` Q Have you ever worked for Broadcom?
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`THOMAS L. CREDELLE
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`Page 16
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` A No.
` Q Have you ever worked for Avago?
` A No.
` Q How about Agilent?
` A No.
` Q Intellectual Discovery Co.?
` A Intellectual Discovery. No.
` Q Are you familiar with Brickell Key
`Investments?
` A Brickell Key? No, I'm not.
` Q How about Juridica Investments; are you
`familiar with them?
` A No.
` Q When were you first retained in connection
`with the IPR involving the '087 patent?
` A I'd have to check my records. I don't
`recall exactly the date I started. It would be
`earlier this year perhaps.
` Q But in 2019?
` A Might have been the end of last year or
`early this year. I don't -- I just don't recall
`when we first engaged.
` Q And were you retained at the same time for
`the '297 patent, as well?
` A I was retained by the firm for help on the
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`THOMAS L. CREDELLE
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`Page 17
`IPRs. I think it was more general than that. The
`two that I worked on are the two that you have.
` Q So I see --
` I'm assuming that I was understanding
`your -- and if -- while -- before we -- I don't want
`to turn this into a memory test.
` A Thank you.
` Q Let me -- let me start by giving you --
`this is Exhibit 2009 from the '279 dec- --
`'279 [sic] IPR, and this is marked -- this is the
`declaration. I believe it's your declaration.
` A '297?
` Q Yes, in the '297.
` Have you seen this document before?
` A Yeah. Looks like -- looks like my
`declaration. Looks like my signature, yes, so --
` Q Okay.
` A -- I've seen this.
` Q And then in the same '297 proceeding, I'm
`going to hand you an exhibit which is Patent Owner's
`Exhibit 2010, which I believe is your CV.
` A Okay.
` THE WITNESS: Do you want to put stickers
`on these or...
` THE COURT REPORTER: Do they have numbers
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`THOMAS L. CREDELLE
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`Page 18
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`on them?
` MR. COLSHER: Yeah. They're -- all of
`these are premarked.
` THE WITNESS: Yep, looks like my CV.
`BY MR. COLSHER:
` Q It looks to me from your -- you know, what
`you wrote in your declaration and your CV, you've
`done a good amount of work with LEDs?
` A That's correct.
` Q That's sort of your -- been your
`specialty, perhaps, over the years?
` MR. HELGE: Object to form.
` THE WITNESS: My specialty is all the
`electronics related to flat-panel displays. So that
`includes flat-panel displays; it includes driver
`circuits; it includes backlights, which includes
`LEDs. So it includes a lot of technology related to
`flat-panel displays, so it's broader than just LCDs.
`BY MR. COLSHER:
` Q Okay.
` And when you referred to the electronics
`related to these flat panels and others, what do you
`mean by "electronics"?
` A For example, the driver electronics,
`video-processing electronics, so -- would be two
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`THOMAS L. CREDELLE
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`Page 19
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`examples.
` Q So in these -- in these electronics that
`you're referring to, these drivers or these video
`processing, your -- what was -- can you describe
`your roles in this context?
` A I will try. It's a 40-year career, so --
` Q Sure. Sure.
` A I started in R&D, so in -- the first
`probably 20 years of my career was in research and
`development in flat-panel display technology. And
`my background is in electronics and optics from MIT,
`so I was involved in the -- in the specification or
`architecture design of driver circuits for LCDs in
`the early days.
` While I was at Apple, it was more involved
`in the interface electronics, the timing controller
`circuits and the -- and how the flat-panel display
`talks to the CPU or the -- or the computer system.
`So that was more at that level.
` When I was at Clairvoyante, we were
`developing pixel architectures that required changes
`in the way you process video data and the way you
`build a flat-panel display. So that involved
`changes in the driver electronic circuits and
`changes in the timing controller circuits to
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`Nichia Exhibit 1017
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`THOMAS L. CREDELLE
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`Page 20
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`implement new architectures.
` Those are some examples.
` Q It's certainly fascinating.
` So in your 40-year-plus career, you know,
`it sounds like you've done a lot.
` Have you ever been involved in the design
`of LED packaging?
` A So I've been involved with LED
`specification of packages for specific products.
` So an example would be at the time frame
`when LCDs were transitioning from fluorescent tubes
`to LED sources for backlighting, that involved
`design or specification of the -- of the package
`that would be used in those -- in those products.
` Often they were long strips of LEDs, so
`the package was amenable to a very skinny, long
`line. Often they were placed in an array, and that
`would require different optics.
` I've worked in high-brightness LEDs,
`high-brightness displays, where the LEDs were
`swapped out to improve the brightness. So that
`involved selecting packages for those applications.
` So I'm very familiar with all the package
`types, but I did not work for a company that
`designed LED packages.
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`THOMAS L. CREDELLE
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`Page 21
` Q So when you say you -- you were involved
`in the specifications, I think is the word that you
`used?
` A Specification and choice.
` Q Specification and choice, and that you
`would hand that off to a third party to develop? Is
`that -- could you -- I mean -- strike that.
` Could you describe the process for your
`involvement in the specifications?
` A Okay. Well, I'll give you one example.
` At Display Engineering, our job was to
`convert a low-brightness LCD to a high-brightness
`LCD. To do that, we had to redesign or change the
`packages, change the LED packages in that product.
`So that involved looking at all of the different
`options of packages that would be appropriate that
`would manage heat, thermal conditions, the optics,
`the light spreading, so all of the details that were
`important for the design.
` My colleagues and I specified those. We
`tested different packages and then selected the type
`that would be used in the product, and then those
`would be produced by a third party.
` Q And this --
` You were just saying "light spreading."
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`Nichia Exhibit 1017
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`THOMAS L. CREDELLE
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`Page 22
`Do you mean like off of like a reflector wall, for
`example? Is that what you're talk- -- or the LED,
`you know --
` A So I don't know how familiar you are with
`LED packages, but they can be flat, they can have
`little domes, they can have optical elements that
`spread the light coming off the LED. And in certain
`product applications, you want a very broad
`spreading of light; in other applications, you want
`it more focused.
` So depending on the application, we would
`select the light spread. And the way that's
`accomplished in an LED package is through shapes of
`walls, lenses that are added, things like that. So
`we would look at those from the spec sheets and
`design, and then physically does it fit, does it fit
`in the space we have.
` Q So when you put those into the -- I guess
`your flat panels --
` A Yeah.
` Q -- or whatever, it fits within your --
` A That's right.
` Q -- into your confines.
` (Reporter clarification.)
` THE WITNESS: Thanks for reminding me.
`
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`Page 22
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`THOMAS L. CREDELLE
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`Page 23
`
` That's right.
`BY MR. COLSHER:
` Q And then you put those into the -- I guess
`the arrays, you were saying, that that's what's
`typically -- these are typically done, is they're --
`your LEDs are mounted in a series of arrays? Is
`that -- is that accurate?
` A Yeah, that they're in an array. It may be
`a linear array; it may be a two-dimensional array,
`but that would be typical of how it's -- how it's
`mounted.
` Q Okay.
` Just so I have the chronology right in my
`head, because I know we've been jumping around, you
`obtained your bachelor's degree in electrical
`engineering from Drexel University in 1969?
` A That's correct.
` Q And then your master's the following year
`in electrical engineering from MIT?
` A That's correct.
` Q And then you went into industry, right, to
`RSA -- RCA.
` A RCA.
` Q Excuse me. RCA.
` And were there for 15, 16 years, I guess?
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`THOMAS L. CREDELLE
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`Page 24
`
` A Yes.
` Q And then that evolved, and then
`Clairvoyante -- we were talking, you know, a couple
`of different jobs. We were talking about
`Clairvoyante a little bit, and then around -- and
`then in 2008, you founded TLC?
` I assume that stands for your -- that's
`your initials?
` A Yes.
` Q And that's what you've been doing up until
`present?
` A From 2008, I've been -- I've had a
`consulting practice called TLC Display Consulting.
`And that's both technical and patent consulting, so
`I've done both types of projects.
` And in that time frame, I also worked
`full-time for a company for about two-and-a-half
`years, so it curtailed some of my other consulting
`work. That was Innova Dynamics.
` Q Okay.
` A But my company has been involved in
`projects all along.
` Q And does TLC Display Consulting Company --
`you said that you had -- some is the, I think --
`correct me -- technical side. That's for companies
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`THOMAS L. CREDELLE
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`Page 25
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`developing products; is that --
` A That would be an example, yes.
` Q Okay.
` And then the other is patent consulting?
` A Patent consulting and also business
`consulting in the field of -- related to flat
`panels. So people would hire me to give them advice
`on maybe a strategy for a product and maybe how to
`market it or where it would be best suited.
` So technical/business as two -- I call
`them technical-related consulting, and then the
`patent is more about this type of work.
` Q If you had to estimate, about what
`percentage would be technical versus -- technical
`and business versus the patent?
` MR. HELGE: Object to form.
` THE WITNESS: Now is mostly patent. My
`last technical consulting job was last year, so I
`haven't done any this year. It's all been the
`patent work.
`BY MR. COLSHER:
` Q Okay.
` And you said the word "marketing." What
`did you mean by "marketing"?
` A Well, I mean what marketing is. Marketing
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`Page 25
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`THOMAS L. CREDELLE
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`Page 26
`a product means deciding where it fits, what it
`should be priced, how it -- how it should be
`designed to meet a certain demand of a market.
`That's what I defined as marketing.
` Q So for your -- like a flat-panel display
`or something, you're helping them bring it to
`market, or is it more -- is it on the finished
`product level or is it on the --
` A I'm waiting for you to stop.
` Q Or is it on a -- sort of a, you know,
`component level?
` A I would say both. I've worked in
`component level and product level. My work at
`Innova Dynamics started as a consulting project on
`touch-screen technology, and it became a full-time
`job.
` But that was -- started as a
`technical/business consulting for how to use a
`certain invented technology in a particular field
`where I have experience and expertise.
` Q And that's in this nanotechnology company
`to develop materials for the LCDs and touch sensors?
` A That's correct.
` Q Okay.
` And I see that you mention one of your key
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`THOMAS L. CREDELLE
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`Page 27
`technical consulting projects was, I believe, for
`Display Engineering, Inc. It's in paragraph 11 of
`your -- of your declaration. I'm not sure where.
` A Yeah.
` Q I suspect it's probably in your CV, as
`well.
` A You said page -- paragraph 11. Yes.
`Okay, I see that.
` Q And this was the design and development of
`high-brightness LED backlit LCDs for display signage
`and other outdoor applications?
` A Yes, I see that.
` Q What is -- I'm sorry, actually digital
`signage.
` A Digital signage.
` Q I'm sorry. I misread that.
` What are you referring --
` What is this digital signage and other
`outdoor applications?
` A It's exactly what it says. It's
`designing, in this case, LCDs that will withstand
`outdoor environments, and that means environmentally
`protecting them and making them bright enough to be
`useful outdoors.
` Competes with what's now more common is
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`THOMAS L. CREDELLE
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`Page 28
`LED signage, which I'm also familiar with. But we
`weren't working on LED signage at that time. This
`was high-brightness LCDs.
` Q And these LCDs and LED, this -- the
`outdoor, you're talking about like, I don't know,
`the electronic billboards and that type of --
` A Any -- you've seen LCDs at bus stops
`sometimes, you'll see electronic signs. So there's
`a lot of signage that's outdoors these days.
` Back in 2008, 2010, LCD was the main type
`of system for smaller signage, where LEDs were
`designed more for the large billboard size. And we
`weren't working on the large billboard size. It was
`up to maybe 80 inches was the -- was the target.
` Q So the LCDs that you were working on were
`around -- were the smaller, up to 80-inch, and then
`you'd use the LEDs for billboards, I think --
` A Other people --
` Q -- you said?
` A Other people would.
` Q Other people would. But --
` A We were not involved in that.
` (Simultaneous speaking.)
` (Reporter clarification.)
` THE WITNESS: You need a whip.
`
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`Page 28
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`THOMAS L. CREDELLE
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`Page 29
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`BY MR. COLSHER:
` Q So when you were working on these
`specifications for these LEDs that you're talking
`about that were, you know, that panel level or array
`level, did they have a reflector and a substrate?
` A Did what have a reflector and --
` Q The LED package.
` A So --
` MR. HELGE: Object to form.
` THE WITNESS: I'm sorry. Could you ask
`the question again, please? There was a little
`distraction there.
`BY MR. COLSHER:
` Q Of course. Of course.
` So these -- when you were designing the
`specifications that you were referring to earlier,
`or involved in the design, would they typically have
`a reflector and substrate?
` MR. HELGE: Object to form.
` THE WITNESS: The backlight system is a
`fairly complex device. It has LEDs, it has
`reflectors, it has substrates. It has all of those
`components.
` The LED packages themselves have a
`substrate and sometimes have reflectors, typically
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`Page 29
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`THOMAS L. CREDELLE
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`Page 30
`have phosphors. So there is a broad array of
`options.
`BY MR. COLSHER:
` Q The specifications that you were working
`on, were you involved in the individual LED
`packages?
` MR. HELGE: Object to form.
` THE WITNESS: I don't -- I guess I don't
`quite understand what you're asking. Did I design
`the packages? I did not design the packages. These
`were purchased components, typically.
`BY MR. COLSHER:
` Q Have you ever worked on the manufacturing
`of LED packaging?
` A No.
` Q Have you ever worked on the development of
`LED packaging?
` A There's only one example. It was a very
`custom design that we did at Display Engineering
`where we mounted bare die to a circuit board, as
`opposed to using a package purchased from the
`outside, and then that was coated with an epoxy
`coating.
` To some extent, you might call that an LED
`package, but it's not a traditional device that you
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`Page 30
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`THOMAS L. CREDELLE
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`Page 31
`would purchase, you know, from Nichia or other
`companies.
` Q Other than that, the custom design, have
`you done any development work for LED packaging?
` A No.
` Q I'm going to hand you what was marked
`previously as Nichia Exhibit 1001 in the '297 patent
`IPR, and that is the '297 patent.
` A I remember that. Thank you.
` Q And have you seen this before?
` A Ye
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