Free Motion for Protective Order - District Court of Delaware - Delaware

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 1 of 24

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 2 of 24

PC .. ATTORNEYS AT LAW

JOHNF. PRESPER

(703) 412-3536

January 12,2007 Via Email and US Mail Jeremy C. McDiarmid, Esq. ROBINS, KAF'LAN, MILLER & CIRESI L.L.P. 800 Boylston Street, 25'h Floor Boston, Massachusetts 02199 Re:
Honeywell Litigation C.A. NOS. 04-1337, -1338, and 01536-KAJ Our Ref: 260613-261775US

[email protected] *BAROTHERTHAN VIRGINIA

Dear Jeremy:

In accordance with paragraph 6 of the Stipulated Protective Order, Optrex hereby serves notice that it intends to disclose information designated as "confidential" under the Protective Order to Richard Knox and Robert Smith-Gillespie to facilitate their services as a consulting andor testifying expert in this case. Mr. Knox's and Mi. Smith-Gillespie's resumes are enclosed wt this letter, ih
Sincerely,

McCLELLAND,

1940 DUKE STREET I A E A D I , LX N R A VIRGINIA 22314 I U.S.A. TELEPHONE: 703-413-3000 I FACSIMILE: 703-413-2220 W . O B L O N . C O M

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 3 of 24

Robert D. Smith-Gillespie

2790 Timberfine Dr. Eugene, Oregon 97405 (541f914-2586 fsg.f'[email protected]

Experienced product and technology development engineer with a diverse background in design and manufacturing of display products focusing on LCD technologies. Roles have included project and team management and technical contributor positions in automotive, aviation and consumer product displays.

Roles and Responsibilities
FPD Design & Consulting LLC
President
2002 Present
Eugene, Ontgon Established display product design and development consulting company specializing in integration of commercial display components into customer specified products. Engineering work includes optical development of enhanced backlight systems for OEM displays, design of camera system for police car applications, and expert witness on LCD mechanical and backlight litigation. Clients include: e Dupont Display Solutions, Torrance, CA [Engineering design & consulting displays (8lM-Present)j e Driven Technoiogies, lrvine, CA [LED backlight design for flight simulator LCD (1/05-3/05)] 0 E3 Innovation, Inc., Phoenix Az [Engineering deslgn & consulting - displays (8/04Present)] 0 QSDM, Inc., Mississauga, Ontario, Canada [Product design-Avionics display assemblies ('02-Present)] e White Electronic Designs, Beaverton, OR [Design of Ruggedized, hi-bright LCD panels (5/03-6/04)3

-

As North American sales and engineer for French display test equipment manufacturer, ELDIM, I lead sales
demonstrations and training on high-end photometric and imaging colorimeter display test systems. * ELDIM, HerouvilleSt, Claire, France [Sales-Optlcaltest equipment for LCDs ('02-Present)I

Patent L#ig&On
e

0

EXp8tf w h 8 S S Morgan Lewis & Brokiius LLP, Wash. D.C. [Patent infringement 7/05 to Present] LG Philips LCD Co. Ltd., v. Chungwa Picture Tubes, Inc.; U S District Court, So. Distric of Calif. .. [Patent Infringement- 5/05 to 7/05 :Settled] Jacobson Holman LLP, Washington D.C. Audiovox v, Epsilon Electronics, lnc. Civil Action No. 03 Civ 8235, Eastern District of N.Y. Shaw Pittman U P and Bingham McCutchen LLP [Patent infringement 6/04 to 7/05 :Seffledj Richard DMk v. ViewSonlc Corp., et. ai., filed in the US. District Court, Eastern DIsbict of Michigan, Southern Division; Case No. 03-74043. [Patent infringement 12/04 7/05 :Seffled]l Alschubr Grossman Stein & Kahn LLP Sharp Corporation v. AU Optronics Corporation, et. al., Case No. C03-04244 MMC filed In the United States District Court, Northern District of California. Deposed, no trial.

-

-

-

-

osen Products LL

1999 2002

Eugene, Oregon Member of senior technical staff reporting to V.P. of engineering. Responsible for management of LCD display technology development, strategic planning and product benchmarking for automotive and aircraft entertainment systems, * Acted as Technology Champion for LCD flat panel displays and DVD source equipment. Worked closely with Korean, Taiwanese and Japanese LCD factories on new products. Developed and directed "Technology Platform Champion" team for coordinating and advancing knowledge base in product critical technology areas. Product engineering manager for business aviation Cabin Entertainment Display Systems.

-

Three-Five Systems, Inc.

Technical Specialist, Displays

1997 1999

Tempe, Arizona Cross-functional specialist working with LCD mechnical and electrical design teams integrating custom LCDs into consumer products. Responsible for injection molded part design and supplier tooling development for polycarbonate light guides. Developed Asian suppliers for molded components. Backlight mechanical design in ProEngineer. Worked as technical wntributor on product designs providing analyses of LCD module designs utiliing

-

-

TN, STN, and FSTN displays and EL, LED, and CCFL backlights.
*

Acted as technical consultant in lighting design, photometrylcolorimetiy, optical materials including birefringent films, holographic reflectors, diffusers, light pipes and color filters.

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 4 of 24

Robert D. Smith-Gillespie
Honeywell, Air Transport Div.
Phoenix, Arizona

Principal Engineer

1992 1997

9

Responsible for mechanical and optical design of the primary displays for the Boeing 777 airplane. Worked closely with Boeing fllght-deck engineers on aircraft fit and packaging and later with lighting engineers to optimize display system performance. Directed supplier process DOE to improve luminance and color ageing performance of 777 backlight. Supported development of automated lamp fabrication process equipment at supplier. Performed sensitivity analyses with Japanese supplier to reduce LCD color performance variation. Led three company development of integrated switch panel for 737-700 MCP. Design incorporated electromechanical switches, high-luminance LCDs and sunlight readable LED annunciators.

Honeywell, Air Transport Dlv.

Sr. Project Engineer

1989 1992

-

Responsible for mechanical design and support of flight deck avionics equipment including mechanical packaging, FEA for chassis and CCA thermal analysis, stress analysis. Lead lighted product development and qualification testing. Worked closely with suppliers to implement product improvement and cost redudion initiatives on LCD modules, optical filters, and mechanical switch components.

Spew Corp. (HoneywellATSD) Manufacturing Engineer
Phoenix, Arltonrr

1985 1989

-

Developed tooling and processes for flight controller manufacturing line including circuit card assembly process optimization, electro-mechanical troubleshooting and supplier quality development.

Eastern Arizona College
Thatcher, Arizona

Instructor, Math & Physics

1983 4985

-

Education
Arizona State University, Tempe,Arizona
BS Mechanical Engineering

May 1989 May 1981

State University of New York, Plafbburgh, NY BA Physics Continuing Educatfon

Classical Optics (PHY 524) - University of Oregon physics department Fall 2003. SolidWorks mechanical design training class. Oct. 2002. Pixelworks HWlSW Developer Training. Sep. 2001. Video Calibrationfor Entertainment Systems. Imaging Science Foundation. April 2001. Liquid Crystal Institute Kent State University. Short course on LCD physics and material. '98. Optical System Analysis with ASAP. Breault Reseach Organization. June '96. Photometry and Colorimetry & Flat Panel Displays. UCLA Extension Short Course. '93I '94.

-

-

Professional memberships
Society for Information Display (SID) Conference organizing committee (2001- 2004):Participate in planning annual display symposia including technical paper review and selection and session chair. Society for Automotive Engineers (SAE) Automotive FDP Metrology Working Group (2000-2002). Professional Ski Instructors of America (PSIA) Certified Level II instructor.

-

-

2

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 5 of 24

Robert D. Smith-Gillespie Publications and awards
Characterizationof Reflective Properties of Displays using Opticai Fourier Transform Photometty. Aerospace Lighting Institute, Feb. 2004 Design Requirements for Automotive Entertainment Displays. 8" Annual Symposium on Vehicle Displays, Soc.for Information Display, Oct. 2001. Wdescreen Formats A Sharper image. Discussion of entertainment video formats published in business aviation industry newsletter Velocity.- Nov. 2001. Development of a High Luminance, High Contrast Fixed Format LCD. Aerospace Lighting Institute Advanced Symposium, Feb. 1996. Fixed Format Liquid Crystal Display Readability in Bright Ambient Environments. iEEE 13th Digital Avionics Systems Conference, Nov. 1994. 777 LCD Backlight Life, SPlE Cockpit Displays Conference, April 1994.

-

Conference Presentation: Rapid Photo-goniomeWc Technique forLED Emission Characterization, Fourth intematlonal Conference on Solid State Lighting, Aug. 2004, Proc. of SPlE Vol. 5530

Awards:

Honeywell Technical Achievement Award. Awarded by Corporate Fellows Committee for outstanding technical contribution in the field of flat panel display backlighting. Feb, 1997.

3

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 6 of 24

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 7 of 24

PROCEEDINGS
SPIE-The
International Society for Optical Engineering

Cockp~t
Darrel 6.Hopper ChairlEditor
7-8 April 1994 Orlando, Florida

lays

Sponsored and Published by SPIE-The International Society for Optical Engineering

Volume 2219

SPlE Uhe Society of Photo-Optical Instrumentation Engineers) is a nonprofit society dedicated to the advancement of optical and optoelectronic applied science and technology.

OA1002364

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 8 of 24

The papers appearing in this book comprise the proceedings of the meeting mentioned on the cover and title page. They reflect the authors' opinions and are published as presented and without change, in the interesrs of timely dissemination. Their inclusion in this publication does not necessarilyconstitute endorsement by the editors or by SPIE.

Please use the following format to cite material from this book: Authork), "Title of paper,' in Cockpit Displays, Darrel C.Hopper, Editor, Proc. SPlE 221 9, page numbers (1994).

Library of Congress Catalog Card No. 94-65802 ISBN 0-8194-1523-5

Published by SPIE-The International Society for Optlcal Engineering P.O. Box 10, Bellingham, Washington 98227-0010 USA Telephone 206/676-3290 (Pacific Time) * Fax 206/647-1445

Copyright O1994, The Society of Photo-Optical Instrumentation Engineers. Copying of material in this book for internal or personal use, or for the internal or personal use of specific clients, beyond the fair use provisions granted by the US. Copyright Law i s authorized by SPlE subject t o payment of copying fees. The TransactionalReporting Service base fee for this volume i s 56.00 per article (or portion thereof), which should be paid directly to the Copyright Clearance Center (CCC), 222 Rosewood Drive, Danvers, h4A 01923. Other copying for republication, resale, advertising or promotion, or any form of systematic or multiple reproduction of any material in this book i s prohibited except with permission in writing from the publisher. The CCC fee code is a8194-1523-5/94/$6.00.

Printed i n the United States of America.

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007
.

Page 9 of 24

. I .

... ...

_ 1 _ c

.

..--..

.

-

I

777 LCD backlight life
Robcrt D. Smith-Cillcspieand Daniel D. Syroid* Honeywell, Inc., 21 I I1 North 19th Ave., Phoenix AZ 85027

* Mr.Syroid is now with Image Qucst Technologies in Fremont, CA
ABSTRACT

Liquid crystal flat paocl displays used in avionics applications require an efTicient, long life, high luminance backlight capable of dimming over a wide luminance range. If properly designed a fluorescent backlighting system should provide maintenance free operation with only minimal reductions in performance for at least 20,000 hours of operation. Tht 9.5 inch diagonal size active matrix LCD primary flight instruments on the k i n g 777 aircraft utilize W i g h t s designed to operate for 30,000 hours while providing a nominal maximum white Icvel of 100 i at the LCD,dropping to 75 a at the L end o f the 3QOOO hour interval.

To ensure reliability goals for the 777 display systems are met, Honeywcll began a three and one-half year life test of the display backlight systems in July of 1992. To date, sisteen backlight assemblies have accumulated over 12,500boun of test operation using a luminance profile that is represenfativc of that esqeaed for 777 flight operations. This paper describes design and operating characteristics, Me test design, and life test results for the backtight systems of the 777 flight deck displays.

1. INTRODUCrION

Honeywell, Ioc. was selected by Boeing to dcvelop the flight deck displays for the new 777 aircraft. The 777 uses si% 57 primary flight instruments, each with a 6.7 s 1. inch active area (9.5 inch diagonal) high resolution full color, active matrix LCD. The backlight system is designed to optimize thc LCD performance by providing maximum color separation while maintaining high spatial luminance uniformicy and high luminous eaciency. The backlights in the 777 primary L displays provide 100 f white luminance output, 2000:l luminance dimming range, wide color gamut,stable operation over all environmental conditions, and an expectcd 30,000 hour operating life. The flight critical nature of the primary displays and the push for continuous improvements in avionics equipment M " s Icad to the obvious need to verify the backlight system design in a Iife cycle tat prior to beginning aircraff flight test. TOdemonstrate the reliability and life espectancy objectives of the backlight systems, a 30,000 hour life test Was initiated in July of 1992. To date, sixTeen backlight asscmblics havc cach accumulated Over 12,500 hours of test operation using the k i n g speciiicd 777 flight operations luminance profilc. With nearly one-half the projected test duration complete, confidcncc in the production backlight system dcsign for the 777 display units has already been established Continued testing will ensure that established system requircmcnts for service in thc avionics environment arc mtt or exceeded.
2. BACKLIGHT DESIGN SUMMARY

Avionics display systems must provide high pcrformancc o w a broad range of operating conditions and thermal environmcnls while providing very high reliability and long lifc. To do so, the display system backlight design must optimiu: luminous cflicicncy whilc niinimizing wight and power. The backlight systcm design for ihe primary flight instruments on thc 777 aircraft incorporatcs scvctal innovations io achieve a 30,000 hour opcraling life without sacrificing cficicncy or opiical pcrforniancc.

OA10023643

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 10 of 24

2.1 Design O v c d c w

To achieve long operating life while maintaining optical pcrformance several design factors must be cafefully balana& For avionics displays, high conversion eficicncy (i.e. low power) and low weight mud be considered along wt Optical ih performance lactors such as luminance uniformity, luminance stability over temperature, maximum and mSnimum luminance levels, and lumen maintenance requircmcnts. The 777 backlight system design muimizes conversion efficienciesat all levels while optimizing lifc exTending factors.
To minimize weight and power, the Honeywell displays usc a single serpentine, hot cathode fluorescent lamp in a E@y reflective integrating cavity with a custom diffuser array and high efficiency drive and control electronics. The h p opcratcs in a selfrcdundant modc to enwrc high rcliabilily. Figure 1 shows an cxplodcd view of thc 777 dif&iy unit with the backlight mounted on its reflector plate. The heated cathode lamp design was chosen for its high lumen &&W, high luminance output, and stable dimming characteristics. The much lower cathode fail voltage in a hot cathode lamp (15 V vs. 100 V for cold cathode) makes hot cathode lamps inhcrently mort efficient than cold cathode lamps during aigh luminance operation. Honeywell's patented singie lamp, alternating cathodc design keeps the number cif cathodes t a o minimum with only one cathode actively heated at any time. Should one cathode fi. however, the d d g n allows al continued aperation on the remaining cathode with nearly full performance.
2 2 Lamp Dcsign Considcrations for t o n g Lifc

TWO primary modes of failure must be considered in fluomcent lamp design for flat panel displays: lumen depnxiation and cathode failure. Lumen depreciation is the reduction in visible iight output at a given arc power lafel and Occus through the time dependent reduction in phosphor UV-to-visible light conversion efficiency and through the of the lamp glass wall by mercury penetration. Cathode failure occurs when the cathode filament emission coating is depleted raising the work function and cathode fall voltage io a level whcre tungsten is sputtered, eventually &ng the filament. Long life can only be achieved by balancing the wear out mechanisms and controlling the rate at which CaCh mechanism, lumen deprcciation and cathode emission coating dcplction, procwds.
Phosphor lumen depreciation is a function of the arc power dissipated in the lamp phosphor per unit phosphor arm. This paramcter, termed phosphor loading, is mcasurcd in mwv/cm*. The lower the phosphor loading, the slower the of lumen depreciation. Unfortunately for the lamp designer. surface luminance depends heavily on phosphor loadin& aS well. Again a balance must be achieved (0 optimize the design for long life. The 777 displays backlight design Simits the initial phosphor loading to 56 mwlcmz over an active length of 980 mm. At end of life, phosphor loading hatass tO 105 mw/cm2 to compensate for phosphor dcpreciation. As the rate of lumen dcpreciation depends also on the chemical stability of the phosphor, the Honeywell design uses stable, high efficiency phosphors to hrther limit lumen depnciation effccts. Cathode failure i a catastrophic failure mode in that no warning of impending failure can be detected by the system T s o minimize the impact on flight operations, the redundant, altcrnating calhodc design allows the backlight to Continue operating at almost full peiformance until a maintenance operation can be perform&. To furlher reduce the possibility Of cathode failure, the cathode is operated at approsimatcly thc ideal cmissive temperatun: of 108OOC thereby p d d i n g copious electrons to thc arc stream while limiting the emission coating evaporation rate. The backlight driver cifcuit is dcsigncd to prevent sputtcring by controlling peak currents thcrcby limiting thc cumnt c m factor to a level below the critical value of 1 7 Finally. a robust filament dcsign pnxlidcs surface area for e x e s emission coating thus favoring .. lumen depreciation as thc means of lamp failure. Lifc tests at Hanqwcll on similar hot cathode lamps have shown filamcnt life of ovcr 30.W hours of actual opcration.
2 Backlight Elcctronics Design Considcrations . 3
As previously statcd, the backlight drive and control electronics play an imporlani role in mceting backlight Service life goals. The backlight clcctronics for fhe 777 displays providc ctoscd loop control of lamp luminance or stable light WyHIt ovcr thc life of the lamp while limiting both the RMS and peak currcnts to thc lamp thereby climinating sputtering effects

at thc cathode. Thc altcrnating cathode drive cffcctivcly doublcs cathodc lifc and provides inhcrent calhodc

in

SPIE Vof. 2219 C o c k p i t D i J p l a y ~ ( 1 9 9 4 ~ 1 2 9 1

OA10023644

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 11 of 24

a single lamp. The usc of closed loop lamp tempcraturc controls allow opcration of the lamp at the maximum efliciency point indcpcndent of environmcntal conditions. Exccss drive capacity is providcd to cornpcnsate for lam lumen decline and allow maximum luminance opcntion and 2000:l dimming capability during the entire backlight lifeX3
3 TEST CONFIGURATION .

To ensure that sufiicient testing had been performed prior to 777 flight test in June of 1994, the displays backlight life tea was initiated using pre-production hardware in July of 1992. The backlight life tcst will reach the h a b y point of 15,000 hour in mid-June of 1994, shonly after the firs flight of 777 aircraft. Figure 2 shows the test configuration which consists of a rack enclosing power supplies, monitoring hardware, and drivers for 16 backlight units that are funaionally equidenl to the production design. A single backlight and reflector assembly is shown in Figure 3 w t the d i a w r ih
removed for clarity.
3.1. Backlight Test Unit Configuration

Each backlight test unit is comprised of a serpentine hot cathode fluorescent lamp (meeting the production hardware specifications)within a reflector housing as shown i n Figurc 3, a front diruser, an active cooling device, a spiral wrapped lamp heater wire, two feed back photo-sensors, and a pair of clcctronic driver circuit cards. The backlight emitting area is 6.8 x 6.8 inches. The test units arc functionally cquivalcnl to the prdluction hardware in terms of electrical openrtion and optical characteristics. The thermal control loop ensurcs that the lamps will operate at the same temperature as tbost in production display units even though the actual thermal environments are significantly different. J%ch unit is also equipped with an hour timer and LED's for indication of cathodc failure and driver output saturation.
3.3 Ancillary Tcst Hardware Configuration

The backlight life test ancillary hardware includes the support rack, monitoring equipment, power supplies, and cycle control unit. A block diagram of the hardware configuration is prcsented in F i y r c 4. The luminance cycle control unit i s programmed to vary the luminance of all 16 units in accordann with (he aforemcntioned 24 hour flight deck luminance cycle which is reproduced in Figure 5 for rcference. To pcrform the environmental stress screen portions of the test. the units are briefly removed from the test rack and transferred to other facilities for vibration and thermal cycling. LikcwiX, the units are periodically removed for luminance and chromaticity mcisurements using a PhotoResearch 1980B spcaroradiomeler.
3.4 Backlight Life Test Parameter Summary

Simulation of actual life cycle conditions in a controllcd lab cnvironmcnt is dificult and compromises must be accepted. For example, in an aircraft service environment, thc displays would sec continual vibration with mechanical and perhaps thermal shocks super-imposed. The backlight life test applies environmental stresses at fixed intervals and dots not attempt to super-impose stressors. Tcst input parameters m a y be divided into four separate categories: luminance variation, electrical transients and interrupts. temperature variation, and mcchanical vibration.
3.4.1 Tcst Input Paramctcrs

While installed in the rack enclosure shown in Figurc 2. the 16 backlight assemblies are subjected to changes in luminance ranging from full-oK to full-on with scvcral intermcdiate dimming lcvels including 0.10% of maximum luminance. At the 8 hour point in the cycle with the tuminancc at 60% the units see a 3 sccond off transient. Additionally, six 50 millisecond intcrmpts arc applicd at various timcs as shown in Figure 5.
At intervals of 100. 1000, and 2500 hours and every 2500 hours thcrcaftcr, the units arc subjccted to monitored thermal cycling and vibration while undcr powcr. The thcrniai cyclc consists of powcr-up to mas,irnurn luminance following 25 minutes of cold soak at 30°C, a 2'Umin. ramp lo +70"C where it is held for 30 minutes powcring-oIr at the end of lhc interval, and a -2'Clmin. ramp down to 40°C. Thc cyclc is rcpcatcd an additional time. Hcatcr and cooler fwIcrions are

292lSPIE Vol. 2219 Cockpit Displays(19941

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 12 of 24

tested during thc sccond cyclc. All units are subjected to a low level random vibration profile, while p w e , for OM: o rd hour per asis during the regular test intcrvals.
3.4.2 Mcasurcd and Calculated Output Parametcn

Monitoring of optical and electrical parameters to cnsure unit hnctionality Will be performed a! start of tat, 100, lm. 2500 hours and at 2500 hour intervals t h e r d c r for at least 30,000 hours of operation. Parameters to be m dddng the test include:
e

e
e
e

Arc power, chromaticity and spectral distribution, luminance, and luminance uniformity. Luminance at masimum (end of life) arc power. Minimum luminance and low luminance uniformity. Accumulated test hours for each individual unit.

Several parameters of interest are calculated to provide additional performance tracking information. These inClUde:
e

* Change in chromaticity from start of test @ella u'v').
e

Luminance uniformity based on 25 pin! measurerncnt whcre Unif = (LmS Lmin) 1Lave Lumen cficicncy in lumens per watt. Percent initial luminance at rated arc powcr.

-

I

3.4.3 Test Failurn Critcria

A backlight failure consists of one or more of the following occurrences:

* Catastrophic failure ofboth cathodes.
0

Failure of luminance at eye refercnce point and scmn center to meet the rated high luminance value. Failure of the BL to meet the minimum rated luminance. Occurrence of noticeable luminance flicker or jumps over the 2000:l dimming range. Failure to meet the luminance uniformity requirement. t= Failure to maintain chromaticity shift to less than or equal to dclta u ' 0.02.

e
e
0

e

4. BACKLIGHT LIFETEST RESULTS As mentioned previously, the life test backlight assemblies havc accumulated an average of over 12,500 hours at this writing. To date, only one catastrophic failurc has occurred and this was due to a handling accident in which the lamp was broken when drop@ to the floor. The unit w promptly replaced and the hour meter reset. In genual, m r , a s performance has followed closely to that prcdictcd based on previous backlight testing. Figures 6,7, and 8 suinmari% the most significant data and include, in two cases, long-tcrm pcrformance predictions based on curve fits to the expcrimcntal data.

The reduction in light output over timc is bcst waluatcd by obscrving the luminance at Screen center at a f d power level. Figure 6 prcsents a plot of the percent of iniiial luminance at 25 arc watts averaged ovcr the I6 backligitI test units. Lamp lumen depreciation has resulted in a drop to 72% of iniiial luminance at 10,OOO hours. It should be noted that the rate of lumcn dcpreciation is decreasing ovcr time with a 10% rcduction occurring in the first 2500 hours. This f o l l m closely previous predictions and is attributable to initial mctions of the phosphor with the mercury and filler gas in the lamp. FoIlowsn reductions in lumen output are the rcsult of reductions in phosphor efficiency through aging and mcrcury darkening of the lamp envelope. It is significant that thc backlight uniformity is changing over time BS ~ 1 1 . Figurc 6 shows the perccnt uniformity increasing (lowcr numbers mcan more uniform luminance) over time wt chc ih curve mirroring that of thc percent initial luminance. One csplanation for this phenomena is that lumen depreciation occurring more rapidly in the bcnd rcgions of lamp thus dcgrading display uniformity, This, in fact, appcars valid as

SPIE Vol. 2219 Cockpit Displays (7994) 293

OA10023646

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 13 of 24

studies of the lamp surface show incrcascd mercury darkening in the bends. Figure 7 shows the variation in chromaticity over time. Included is a rough prediction of the trend up to 30,000 W . Unfortunately, lhe accuracy of color measurement over a prolongcd time has lead to some uncertainty to the precision of this data and the predictions based upon it. The prediction curve has becn fit to the last four data points to reduce tbt influence of photometric calibration changes. Based on the projections, the change in chromaticity at the m r rrlativc to initiai values will reach a delta u'v' of 0.020 at only 20,000 hours. At 30,000 hwrs the color will have changed Wiy 0.002delta uV units more to 0.022. [Delta u'v' is the length of a radial from the initial CIE 1976 coordinates to thosc a t some later time.] The LCD calor filters, however, modcralc the fled of changes to B chromaticities resuiting in a L lesser color delta when measured at the LCD. Simulationshave shown that a del@uY of 0.022 at thc diffustr results in a change of color at the LCD of only 0.017 units, The most significant w i t of the testing is presented in Figure 8 which presents measured and predicted maximum display luminance at the LCD surface as a h e t i o n of time. Based on an exponential curve fit to the Iuminanct data and using the measured transmittance of the LCD assembly, the LCD luminance will stay above 100 fL for mre t a 20,000 hn hwrs and a h v c 75 L out to 30,000hours. The display units set a maintenance required flag when the l u m i n a ~ x ! falls below 75 fL. Based on this prediction, the life goals for the Honcywcll 777 displays will be met if o p e m t i ~ anttinuts without catastrophic failure. After 200.000 houn of combincd operation, no catastrophic operational failures have

occurred.
CONCLUSION

Improvements to lamp design and fabrication processes which will bc implemented on flight hardware should have a positive impact of pcrformance. Additional life improvcmcnts should also be SCen in service since early assumpliorri underestimated LCD transmission thus setting Iuminancc Icvcls roughly 20% higher than actually needed for the required display performance. The resulting reduciion in phosphor loading should imprwc lumen maintenance significantly. The lifetest results presented here demonstrate that the fluorescent backlight syslems for the 777 primary flight instruments reliably meet all established performance requirements. Life predictions based on the backlight life test data show that Honeywell is well on a path of achieving the 30,000 hour operating life goal.

ACKNOWLEDGEMENTS
The auIhon wish to acknowledge John F. Waymouth for his wisdom and guidance on fluorescent lamp principles, Wayne Clark for his early influence on design philosophy, Joe Ruby for his dcvelopment efforts and expertise on the lamp driver circuit design, Steve Artrciter, Peter Brown, Ray Cleland, and Phit Imber for their ourstanding technical dtvclopment and test support, Edward Delanty, Dr. Alan Jawbsen. and Donald Newsame of the Boeing 777 Display Technology group for their direction on the establishment of performance and lifetest objectives, and finally, George Csoknyai of LCD Lighting for his support in providing lamps to test.

REFERENCES
I . Electric Discharge Lamps, John F. Waymouth. M.I.T. Prcss. 1971 2. U.S.Patent 4,998,015 Fluorcscent Lamp Dimmer 3. U.S.Patent 5,027.034 Alternating Cathodc Fluorescent Lamp Dimnier

'

294 15PIE Vof. 2219 Cockpit Displays (1994)

Case 1:04-cv-01338-JJF

Document 713-2
.

Filed 02/15/2007
-

Page 14 of 24

Figure 1. Esplodcd view of 777 flat panel display unit showing backlight assembly.

Figure 2. Photograph of backlight lifc tcsl facility (display unit backlights at lcn) with diffusers inslalied over operating displays.

,
SPlE Vol. 2219 Coc&pitDisplays (1994) / 295

OA10023648

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 15 of 24

Figure 3. Close-up photograph of Iifc test backlight assembly with diffuser removed to show lamp and reflectiveenclosure.

BACKLIGHT LIFE TEST HARDWARE BMCK DIAGRAM
WI
*o

m

I

296 I S P f E Voi. 2.7 I9 Cockpit Displays ( I 994)

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 16 of 24

d

k

40

e M
20
10

Io

Figure 5. Life test luminance profile based on w i n g 24 hour luminance profile for 777 operation.

Figure 6. Average variation in pcrcent initial luminancc at 25 arc watts and luminancc uniformity St diffuser test duration.

SPlf

Case 1:04-cv-01338-JJF
,

Document 713-2

Filed 02/15/2007

Page 17 of 24

__

.. ..

0.025

0.02

0
0
WX, MM,

7Mo

loo00

IYU)

lsO(y,

l7Mo

Xmo

P X W ,

Zso

?lMo

Moo0

a a p dIlWY

Figure 7. Average variation in chromaticity at diffuser (in CIE 1976 units) Over test duration.

0

1

Figure 8. Measured and predicted display luminancc at thc LCD surface for 30,000hour period.

298 I S P I E Vol. 2219 Cockpit Displays (1994)

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 18 of 24

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 19 of 24

2800 LASALLE PLAZA 800 LASALLE AVENUE MINNEAPOLIS. 55402 2 0 1 5 AlN TEL: 612-349-8500 FAX: b12-339-4

I

AhW N.SOI;TiCH
612-349-8475

February 9,2007

VIA FACSIMILE AND MAIL
John F. Presper Oblon, Spiv&, McClelland, Maier & Neustadt, P.C. 1940 Duke Street Alexandria, Virginia 223 14

Re:

Honeywell International Inc., et al. v. Apple Computer, Inc., et ai. Our File No.: 019896-0229

Dear Mr. Presper:

I write in follow-up to our prior correspondence and our February 8th meet and confer relating to Optrex's intention to utilize Robert Smith-Gillespie as a consultadexpert in this matter. As mentioned in my letter of February 5, and as reiterated in our meet-and-confer, Honeywell has legitimate concerns relating to Optrex's designation of Mr. Smith-Gillespie. Mr. Smith-Gillespie worked at Honeywell from 1985 to 1997 and was exposed to confidential Honeywell material and potentially attorney-client communications.
As we discussed on February 8th, Honeywell is willing to work with Optrex to reach a mutually acceptable resolution to this issue. Honeywell would l i e to be assured that Mr. Smith-Gillespie will serve as a true consultantlexpert, and not as a fact witness. In that regard, Honeywell is willing to reserve its objection to Mr. Smith-Gillespie under the Stipulated Protective Order if Optrex and Mr. Smith-Gillespie agree to the following:

1.

Mr. Smith-Gillespie and Optrex confim (by signing below) that Mr. Smith-Gillespie has not disclosed, and will not disclose, any information to Optrex (or any other source) that he learned or obtained while employed at Honeywell. This information shall include but is not limited to: (a) any personal knowledge Mr. Smith-Gillespie obtained during his employment at Honeywell, including information from nonpublic documents, meetings, conversations, and correspondence; and (b) any documents or materials from Mr. SmithGillespie's personal files that were created during his employment at Honeywell. The factual basis for any opinions Mr. Smith-Gillespie provides to Optrex in connection

2,

with this matter shall be based solely and exclusively upon the following: (a) publicly
available information; (b) documents produced in this litigation; and (c) deposition testimony provided in this litigation. Moreover, Mr. Smith-Gillespie shall not rely in

MP3 20212937.1
T L
A

N T * . B O

S T 0 N . L

0 S

A N G E L E S

M I N N E A P O L I S

N A P L f S . S

A

I N T P A U L . W A S H I N G T 0 N , D . C .

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 20 of 24

John F. Presper February 9,2007 Page 2

any way upon information learned or obtained during his employment wt ih Honeywell.
If Optrex and Mr. Smith-Gillespie will agree to these terms, please indicate such agreement by counter-signing below and returning this letter to me. Please be advised that if Optrex andor Mr. Smith-Gillespie will not agree to these terms, Honeywell will have no choice but to raise this issue with Court. Given that Honeywell would have to make such a filing with the Court on or before Thursday, February 15, I would appreciate if you would contact me by the close of business on Tuesday, February 13 to c o n f i i Optrex's position on this issue. I look forward to hearing fiom you. Sincerely,

ROBINS, KAPLAN, MILLER & CIRESI L.L.P.

AmyN. oftich
cc:

"a-AP

Matthew Woods Alan McKenna

MP3 20212937.1

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 21 of 24

**

J O B STATUS R E P O R T

**

A S OF

FEB 09 2007 1 7 : 3 6

PAGE. 0 1

R. K. kl. 81 C.
JOB $080

LLP

DATE
001 2/09

TIME 17:36

TO/FROM MODE 917034132220 EC--S

MIN/SEC PGS 00' 18" 002

STATUS OK

1

ATTORNSYSAT

LAW

1

February 9,2007
VIA FACSIMILE AND MAIT

John F. Presper Oblon, Spiv&, McClellmd, Maier & N e d , P.C. 1940 Duke Street Alexandria, Virginia 223 14

Re:

Honeywell hernational Lnc., et al. v. Apple Computer, Inc., et al. Our File No.: 019896-0229

Da Mr. Presper: er
1write in follow-up to our prior correspondence and our February 8th meet and coder relating to Optrex's intention to u i i e Rob& Smith-Crillespie BS a consuItanffexpert in t i tlz hs m t e . As mentioned in my 1 atr of February 5, and as reiterated in OW meet-and-coder2 r Honeywell has legitimate concerns relating to Optrex's designation of M .Smith-Gillespie. Mr. Smith-Gillespie worked at Honeywell fkom 1985 to 1997 and was exposed to confidential Honeqwell material and potentially attorney-clientcommunications.
As we discussed on Febnrary Sth, Honeywell is willing to work with Optrex to reach B mutually acceptable resolution to this issue. Honeywell would like to be assured that Mr. Smith-Giliespie will serve as a true consuItantlexpert,and not as a fact witness. I that regard, n Honepvell is willing to reserve its objection to Mr. Smith-GilIespie under the StipuIated x Protective &der if Optrex and M .Smith-Gillespieagree ta the following:

I.

Mr. Smith-Gillespie and Optrex w n f m (by signing below) that Mr, Smith-Gillespiehas not disclosed, and will not disclose, my informationto Optrex (or any other source) that he learned or obtained while employed at Honeywell. This information shaH include but is not limited to: (a) any persod knowIedge Mr. Smith-Gillespie obtained during his employment at Honeywell, including information fnsm uanpublic documents, meetings, conversations, and correspondence;and @) any documents or materials from Mr. SmithCrillespie's personal files that were created during his employment at Honejwell. The factual basis for any opinions Mi. Smith-GiIlespie provides to Optrex in connection wt this matter shall be based solely and exclusiveIy upon the following: (a) publicly ih available information; (b) documents produced in this litigation; and (c) deposition testimony provided in this litigation. Moreover, Mr. Smith-Gillespie shall not rely i n

2.

A

T L A H T A . ~ O S S O H .

MP3 20212937.1

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 22 of 24

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 23 of 24

'FEB, 13, 2007" 10:32Atvl

"CBLOIU

SPIVAK

NO. 686

P, 2

February 13,2007 VIA F A C S m E

Amy N.softich,'Esq. ROBINS, K . A J ? L ~MILLER & CIRESI LLP. ,
2800 M a l l e Plaza 800 LaSaUe Avenue Minnapalis, M N 55402

P.G

ATTORNEYS AT LAW
WDRNJ Ouis M.

(703) 812-7023
[email protected]

Re:

Honeywell Litigations C.A. NOS.04-1337, -1338,and -1536-KAl 0201613-261775US

Dear Amy,

This letter responds to your Ietter to J ~ h Prespert ofFebruary 9,2007. We n appreciate Honeywell's wilIingness to work with Optrex to make Mr. Smith-Gillespie available as a ~onsultant.Several aspects of your proposal, however, are troubXing to Opeex.
First and foremost is Honepell's position that it is willing to "reserve its objection" to Mr. Smith-Gilllespieif Optrex and Mr. Smith-Gillwpie agree to certain, conditions. Vptrex cannot accept any such resenration of rights by HoaeywelL Such reservationprejudices optrex's ability to work with W. Smith-Gillespieby forever hiolding out the possibility that Honeywell may Eater object to Mr. Smith-GiLlespie h e r s~griificant and effort have bem expended. Optrex therefore m s insist that time ut Honeywell at this time either object or not object to Mi. Smith-GiIle*e,

Second, Honey-wdl expresses concern that Mi. Smith-GilXespieonly work as a consulmtlexpert and not as a fmt witness. While Optrex presently intends that Mr. Smith-Gillespie serve only as an exy"rt/consultmt, @&exwill not foreclose the possibility of also calling Mr. Smitk-GUespie as a fact witness in the fbtme should it be necessary to do so. For example, as you are aware, Mr. Smith-Giflespie also worked at Baneywelll on the Boeing 777 program, and Optrex presmtly does not know whether any ofthe relevant testbony provided by the inventors concerning this program might differ ;ffiomMr. Smith-Gllespie's own understanding of the program.

Third, Optrex is WiIling to agree that Mr. Smith-Gillespieshall not disclose to Optrex (or other defendants) confidential Honeywell infomation learned during his employment at Honeywell to the extent such information h s been been majntaked a coni?dential by I.lomywel1. Optrex c m o t agree to Honeywell's broader proposaIs
becase they are not so knited.

1 DUKE STREET 'w
TELEPHONE: 3-3000 703-41
c

h?WW.WA,

VIRGINIA 223141 U . S . R
# W.OB1ON.COM

FACSIMILE: 703-413-2220

PAGE 213 * RCW AT 113120079:33:43 AM [Central Standard Time]* S ~ : ~ P g R i G H *TDN1S:E12* ~ S l ~ : 7 0 3 4 ~ 3 DURATION ~mu,ss):D~,~l F~~ 2~~0*

Case 1:04-cv-01338-JJF

Document 713-2

Filed 02/15/2007

Page 24 of 24

WO, 686

P. 3

!

Amy N.Softich, Esq. ROBINS, K;4pLAN, MILLER & ClRESZ L.L.Pp, Eebmary 13,2007 Page 2

Finally?Mi, Smith-Gillespie's own work cxpexiences cannot be, entirely separated Eom my expert report. Any expert report itself can certainly be limited to p~bricly availableinformation and in50rmationproduced during the litigation. However, sbould rebuttal testimony or answers to Honeywell cross-examination calf on Mr. SmithGilleSpie to refer to his personal andlor confidential experiences fiom his work at Honeywell, M. Smith-GiUespie shudd be Eree to sa testify.
Zn summary,we look foxward to discussing these matters w i you -ex ~ and amicably addressing our ditferences ifpossible.

With bast regards,

very truly yours,

OBLON, SPTVAK, McCLELLAND, MASR & NEUSTADT, P-C.

*tm,
Andrew M. CMis

iGzzk

PAGE 313 RMAT ~ ~ 3 1 9:33:430 MI[CentralStandard Time]* S ~ : ~ P D R I G H *TDNIS:612* C S I D ~ 7 ~ ~D4U ~ T~I ~ N ~ 0 * C ~~ 7 F~~ O~

~ r n f l . s s ~ : O ~ g O 8