Trial Testimony Presented by: T. Kim Parnell, PhD,PE Parnell Engineering & Consulting (PEC)

Transcription

1 JF Microtechnology ZIGMA Product Technology Overview & Analysis Trial Testimony Presented by: T. Kim Parnell, PhD,PE Parnell Engineering & Consulting (PEC)

2 T. Kim Parnell, PhD,PE - Biography Education: Stanford University, Ph.D. and Masters, Mechanical Engineering Georgia Tech, BES (Highest Honors) Tr. Ex

3 T. Kim Parnell, PhD,PE - Biography Teaching Experience: Santa Clara University, Mechanical Engineering Taught courses in materials, design, and manufacturing applications and finite element analysis Stanford University, Mechanical Engineering Taught graduate courses in mechanics Stanford University, Composites Design Program Tr. Ex

4 T. Kim Parnell, PhD,PE - Biography Work Experience: MSC.Software Corporation Rubicor Medical Exponent Failure Analysis Associates SST Systems Stanford University ATT Bell Laboratories General Motors Tr. Ex

5 T. Kim Parnell, PhD,PE - Biography Work Experience: Parnell Engineering & Consulting (PEC) Principal & Founder Analysis of design, manufacturing and failure of mechanical and electrical components FEA analysis and simulations Reliability assessments Additional teaching and lecturing activities Tr. Ex

6 T. Kim Parnell, PhD,PE - Biography Other Qualifications: Registered Professional Mechanical Engineer State of California ASME Fellow IEEE Senior Member IEEE Santa Clara Valley Section Past-Chair Over 12,000 members in Silicon Valley IEEE Consultants' Network of Silicon Valley Past-Chair; Board of Directors ASM and SAE Member Tr. Ex

7 Tasks Performed Form opinions on whether Zigma infringes the '866 patent Form opinions on whether the '866 patent is invalid Tr. Ex

8 Materials Reviewed Reviewed documents and products 866 Patent Prior Art References Documents describing ZIGMA ZIGMA product samples and models Reviewed deposition transcripts Spoke with JF Microtechnology Engineers Considered professional experience Analyzed the Brown and Andres opinions 8

9 Person of Ordinary Skill in the Art Technical skill level necessary to make and use the claimed apparatus for electrically connecting a lead of the integrated circuit to be tested to a corresponding terminal of a load board at a test site of the 866 patent at the time of filing (2004) Technical skill level: an undergraduate degree in Mechanical or Electrical Engineering and 3 years of experience working in the development of integrated circuit testing or integrated circuit manufacturing, or an equivalent combination of education and experience in related fields 9

10 Summary of Opinions Zigma product does not meet claim 1 because: Functional Differences: Sliding is not approximately eliminated, motion is rotation with controlled, substantial sliding Structural Differences: No engagement between contact and housing wall, differences are substantial in function, way, and result Zigma product does not meet claims 2-4 for the same reasons as claim 1 Zigma product also does not meet claim 2 because: Zigma contact is L-shaped Zigma product also does not meet claim 4 because: Zigma contact has no protrusion 10

11 Functional Requirement - Not Met The Court s construction of the function is not met in the accused Zigma products because: sliding motion across the terminal is approximately eliminated The Zigma contacts rotate and slide the sliding is significant and controlled. 11

12 Rocking Chair Analogy Rolling occurs when you rock gently (central contact point does not translate) 12

13 Rocking Chair Analogy Sliding occurs when you push the chair across the room (central contact point does translate) 13

14 Finite Element Analysis (FEA) Loading Steps Installation of contact and elastomers into housing accounting for interference fits Installation of load board, bring flush with housing base, compress contact and elastomers Downward loading of chip lead against contact by 0.2 mm Tr. Ex. 187, p. 8 14

15 Animation Engaging IC Lead 0.2mm vertical movement at IC lead Significant compression of elastomers Load board contact sliding away from chip lead vertical displacement 0.2 mm Click animation in Slideshow mode to Play Tr. Ex. 187, p

16 Zigma Contact: Rotation + Sliding Sliding displacement is significant overall Sliding displacement is significant compared to rotation Short Wiping Chip lead Contact Center of Curvature Zigma sliding is not substantially eliminated! Final Board Contact Initial Board Contact Tr. Ex. 187 Sliding Direction 16

17 Superposed: Initial & Final Connector Positions Initial Position Usual Zigma Motion Final Position Tr. Ex

18 Connector Motion: Rotation Only Initial Position Center of Curvature Translation for Pure Rotation Tr. Ex. 187 Rotation Only End Position 18

19 Connector Motion: Rotation Only Initial Position Center of Curvature Translation for Pure Rotation Rotation Only End Position Tr. Ex

20 Connector Motion: Sliding Only Initial Position Center of Curvature Translation for Pure Rotation Tr. Ex. 187 Rotation Only End Position 20

21 Connector Motion: Sliding Only Center of Curvature Movement for Pure Rotation Center of Curvature Movement for Sliding Only to Final Position Reverse (away from IC) Sliding Only Final Position Rotation Only Position Tr. Ex

22 Zigma sliding movement Horizontal displacement (mm) of Contact on load board (first and last node in contact) as chip lead fully engages (0.2mm vertical) Approximately 0.132mm sliding of Load Board contact nodes (away from chip) Tr. Ex. 187, p