PTO/SB/57 (O2-O1)
`Approved for use through 01/31/2004. OMB 065 10033
`Patent and Trademark Office, U.S. DEPARTMENT OF COMMERCE
`
`QUEST FOR REEXAMINATION TRANSMITTAL FORM
`TO‘
`Mail Stop Ex Parte Reexam
`Attorney Docket No. 09325.0013
`‘ Commissioner for Patents
`Attorney Customer Number: 22,852
`Date: March 24, 2006
`P.O. Box 1450
`3 Aexandria, VA 22313-1450
`
`5 1.
`
`This is a request for ex parte reexamination pursuant to 37 CFR 1.510 of patent number
`6,404,480 issued June 11, 2002.
`third party requester.
`The request is made by:
`[:1 patent owner.
`he name and address of the person requesting reexamination is:
`Jonathan Min Hu Huang
`Chi Mei Optoelectronics Corporation
`No. 2, Sec. 2, Huanshi Road
`Tainan Science-Based Industrial Park
`Tainan County 74144
`Taiwan REPUBLIC OF CHINA
`3/24/06
`. X] a. A check in the amount of $2,520.00 is enclosed to cover the reexamination fee,
`37 CFR 1.20(c)(i); or
`
`--I
`
`iiiliiilliiliiiiiiiiiiiliifii03/24/06
`
`660 us. PTO
`6490007985
`
`Deposit Account No. 06-0916.
`
`. E] Any refund should be made by [:1 check or by [Z credit to Deposit Account No. 06-0916.
`37 CFR 1.26(c)
`
`.
`
`, 6.
`5 7.
`l
`
`A copy of the patent to be reexamined having a double column format on one side of a
`separate paper is enclosed. 37 CFR 1.510(b)(4)
`
`[:1 CD-ROM or CD-R in duplicate, Computer Program (Appendix) or large table
`l:] Nucleotide and/or Amino Acid Sequence Submission:
`Ifapplicable, all of the following are
`necessary
`a. Cl
`Computer Readable Form (CRF):
`b. Specification Sequence Listing on:
`i BOD-ROM (2 copies) or CD-R (w copies); or
`ii
`I:]paper
`
`c. D
`
`Statements verifying identity of above copies
`
`l 8.
`
`(X A copy of any disclaimer, certificate of correction or reexamination certificate issued in3"th'“e‘‘* 3*’
`patent is included.
`
`5 9.
`Reexamination of claims 1, 2, 4, 5, 11, 12, 14, and 15 is requested.
`10.E§l A co of eve
`atent or rinted ublication relied uon is submitted hereith incluin
`
`Page 1 of 2
`
`Exhibit 1003, page 1
`
`

`
`listing thereof on Form PTO SB/08.
`
`11.lZ An English language translation of all
`or printed publications is included.
`
`includes at least the following items:
`tantial new question of patentability based on prior
`
`Eric J. Robinson, Esq.
`Robinson intellectual Property Law Office PMB 955
`21010 Southbank Street, Potomac Falls, VA 20165
`Date of Service: March 24, 2006; or
`
`16. The patent is currently the subject of the followin
`g concurrent proceeding(s):
`a. Copending reissue application Serial No. .
`b. Copending reexamination Control No. .
`c. Copending Interference No.
`
`[:1 For Patent Owner Requester
`
`E] For Third Party Requester
`
`Exhibit 1003, page 2
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Group Art Unit: To Be Assigned
`
`Examiner: To Be Assigned
`
`) ) ) ) ) 3
`
`) ) ) ) ) ) )
`
`IN THE EX PARTE REEXAMINATION
`REQUEST OF:
`
`U.S. Patent No. 6,404,480
`
`Issued: June 11, 2002
`
`Patentee: Yoshiharu HIRAKATA et al.
`
`Control No.: To Be Assigned
`
`Filed: March 24, 2006
`
`Title: Contact Structure
`
`Mail Stop Ex Parte Reexam
`Commissioner for Patents
`P.O. Box 1450
`
`Alexandria, VA 22313-1450
`
`Sir:
`
`REQUEST FOR EX PARTE REEXAMINATION
`
`Third Party Requester Chi Mei Optoelectronics Corp. (“Requester”) respectfully
`
`requests an ex parte reexamination of U.S. Patent No. 6,404,480 (“the ‘480 patent”),
`
`which issued on June 11, 2002 to Yoshiharu Hirakata et al. and lists Semiconductor
`
`Energy Laboratory Co., Ltd. ("SEL”) as the assignee. The ‘480 patent is a subject of the
`
`case Semiconductor Energy Laboratory Co., Ltd. v. Chi Mei Optoelectronics Corp. et
`
`al., Civil Action No. C 04 4675 MHP (N.D. Cal.) There has not yet been a trial in the
`case.
`
`Exhibit 1003, page 3
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`This Request is accompanied by the following:
`
`(1)
`
`(2)
`
`(3)
`
`(4)
`
`(5)
`
`The appropriate fee payment of $2,520.00 under 37 C.F.R. § 1.20(c);
`
`A statement pointing out each substantial new question of patentability
`based on the prior art;
`
`An identification of every claim for which reexamination is requested, and
`a detailed explanation of the pertinency and manner of applying the cited
`prior art to every claim for which reexamination is requested;
`
`A copy of each of the prior art references discussed in this Request,
`including English language translations of four Japanese references, and
`a listing thereof on Form PTO SB/08;
`
`A copy of the entire ’480 patent (attached as Exhibit A) including the front
`face, drawings, and specification/claims, in double column format, along
`with a Certificate of Correction that was issued for the ‘480 patent; and
`
`A certification that a copy of this Request for Ex Parte Reexamination in its
`entirety has been served on counsel of record, Eric J. Robinson, Robinson
`intellectual Property Law Office PMB 955 21010 Southbank Street
`Potomac Falls, VA 20165, on March 24, 2006, via first class mail.
`
`Exhibit 1003, page 4
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`The following is a Table of Contents for this Request for Ex Parte Reexamination.
`
`TABLE OF CONTENTS
`
`I.
`
`Identification of the Claims for Which Reexamination is Requested............... ..4
`
`ll. List of Prior Art References that Raise Substantial New Questions of
`Patentability for Claims 1, 2, 4, 5, 11,12, 14, and 15 of the ’480 Patent ................... ..4
`
`Application of the Prior Art to the Claims ....................................................... ..6
`III.
`A. Summary of the Substantial New Questions of Patentability for Claims 1, 2, 4, 5,
`11,12, 14, and 15forthe ’48O Patent ......................................................................... ..6
`B. Claims 1, 5, 11, and 15 are unpatenable under 35 U.S.C. § 102(b) as anticipated
`by the ‘333 publication, or under 35 U.S.C. § 103(a) as obvious over the ‘333
`publication, alone or in combination with Aart or the ‘474 patent ............................... ..7
`1. Claims 1, 5, 11, and 15 are unpatenable under 35 U.S.C. § 102(b) as
`anticipated by the ‘333 publication ......................................................................... ..7
`2. Claims 1, 5, 11, and 15 are unpatenable under 35 U.S.C. § 103(a) as obvious
`over the ‘333 publication, alone or in combination with Aart or the ‘474 patent .... ..13
`C. Claims 1, 2, 5, 11, 12, and 15 are unpatenable under 35 U.S.C. § 102(e) as
`anticipated by the ‘456 patent .................................................................................. ..15
`D. Claims 1, 4, and 5 are unpatenable under 35 U.S.C. § 102(e) as anticipated by
`the ‘474 patent ......................................................................................................... ..2O
`E. Claims 1, 2, 4, 5, 11, 12, 14, and 15 are unpatenable under 35 U.S.C. § 102(b)
`as anticipated by the ‘530 publication ...................................................................... ..23
`F. Claims 1, 5, 11, and 15 are unpatentable under 35 U.S.C. § 103(a) as obvious
`over Aart in view of the ‘333 publication ................................................................... ..28
`G. Claims 1, 2, 4, and 5 are unpatentable under 35 U.S.C. § 103(a) as obvious over
`the ‘41 5 publication in view of the ‘51O publication or the ‘941 patent...................... ..32
`H. Claims 2 and 12 are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`‘333 publication in view of the the ‘941 patent .......................................................... ..37
`I.
`Claims 4 and 14 are unpatentable under 35 U.S.C. § 103(a) as obvious over the
`‘333 publication in view of the ‘415 publication, the ‘530 publication, or the ‘183
`publication ................................................................................................................ ..38
`
`IV.
`
`Substantial New Questions of Patentability ...................................................40
`
`V. Conclusion ............................................................................................................40
`
`Exhibit 1003, page 5
`
`

`
`Request for Reexamination of u.s. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. O9325.0013
`
`Identification of the Claims for Which Reexamination is Re uested
`
`Reexamination is requested for claims 1, 2, 4, 5, 11, 12, 14, and 15 of the ‘480
`
`patent. Of these, claims 1 and 11 are independent. A copy of the entire ’48O patent is
`
`attached hereto as Exhibit A, including the front face, drawings, and specification/
`
`claims, in double column format, along with a Certificate of Correction issued for the
`
`‘480 patent.
`
`List of Prior Art References that Raise Substantial New Questions of
`Patentability for Claims 1, 2, 4, 5, 11, 12, 14, and 15 of the ’480 Patent
`
`Requester relies on the prior-art documents listed below in support of this
`
`request for ex parte reexamination. None of these references except the admitted prior
`
`art was before the Examiner during prosecution of the ‘480 patent. The prior art
`
`documents are listed on an accompanying Form PTO/SB/O8.
`
`The ‘480 patent is a division of U.S. Application No. 09/361,218, now U.S. Patent
`
`No. 6,177,974, which is a division of U.S. Application No. 09/046,685, now U.S. Patent
`
`No. 5,982,471. To the Requester’s knowledge, none of the listed prior art documents
`
`except the admitted prior art was before the Examiner during prosecution of the
`
`aforementioned divisional applications.
`
`Moreover, the following pending U.S. applications claim the benefit of the ‘480
`
`patent: U.S. Application No. 10/125,394, filed on April 19, 2002; U.S. Application No.
`
`10/453,684, filed on June 4, 2003; U.S. Application No. 11/199,125, filed on August 9,
`
`2005; and U.S. Application No. 11/199,135, filed on August 9, 2005. To the
`
`Requester’s knowledge, at least one of the listed prior art documents is before the
`
`Examiner in the pending applications. Three of these pending applications currently
`
`-4-
`
`Exhibit 1003, page 6
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`have an outstanding Office Action (U.S. App. No. 10/125,394, U.S. App. No.
`
`11/199,125, and U.S. App. No. 11/199,135).
`
`In the applications having outstanding
`
`Office Actions, the Examiner has rejected at least some of the claims under 35 U.S.C.
`
`§ 102 based on Japanese Patent Publication No. JP 5-243333, which is one of the
`
`listed prior art documents.
`
`0
`
`Japanese Patent Publication No. JP 5-243333 including its English
`
`language translation (“the ‘333 publication”) (copy attached at Exhibit B)
`
`o U.S. Patent No. 5,757,456 (“the ‘456 patent”) (copy attached as Exhibit
`
`C), along with priority documents JP 8-250745 (“the ‘745 publication”)
`
`(copy attached as Exhibit D) and JP 8-254686 (“the ‘686 publication”)
`
`(copy attached as Exhibit E), including their English language
`
`translations
`
`U.S. Patent No. 5,625,474 (“the ‘474 patent”) (copy attached as Exhibit
`
`F)
`
`Admitted Art (“Aart”) from the ‘48O patent
`
`PCT Publication No. WO 97/10530 including its English language
`
`translation ("the ‘530 publication”) (copy attached as Exhibit G)
`
`Japanese Patent Publication No. JP 6-289415 including its English
`
`language translation ("the ‘415 publication”) (copy attached at Exhibit H)
`
`Japanese Patent Publication No. JP 6-308510 including its English
`
`language translation (“the ‘51O publication”) (copy attached at Exhibit l)
`
`o U.S. Patent No. 5,486,941 (“the ‘941 patent”) (copy attached as Exhibit
`
`J)
`
`Exhibit 1003, page 7
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`o
`
`Japanese Patent Publication No. JP 5-241183 including its English
`
`language translation (“the ‘183 publication”) (copy attached at Exhibit K)
`
`Application of the Prior Art to the Claims.
`
`A.
`
`Summary of the Substantial New Questions of Patentability for
`Claims 1, 2, 4, 5, 11, 12, 14, and 15 for the ’480 Patent
`
`The following list summarizes the substantial new questions of patentability
`
`raised by the prior art cited in this reexamination request. Detailed explanations follow
`
`in subsequent sections.
`
`o Claims 1, 5, 11, and 15 are unpatenable under 35 U.S.C. § 102(b) as
`
`anticipated by the ‘333 publication, or under 35 U.S.C. § 103(a) as
`
`obvious over the ‘333 publication, alone or in combination with Aart or
`
`the ‘474 patent.
`
`Claims 1, 2, 5, 11, 12, and 15 are unpatenable under 35 U.S.C.
`
`§ 102(e) as anticipated by the ‘456 patent.
`
`Claims 1, 4, and 5 are unpatenable under 35 U.S.C. § 102(e) as
`
`anticipated by the ‘474 patent.
`
`Claims 1, 2, 4, 5, 11, 12, 14, and 15 are unpatenable under 35 U.S.C.
`
`§ 102(b) as anticipated by the ‘530 publication.
`
`Claims 1, 5, 11, and 15 are unpatentable under 35 U.S.C. § 103(a) as
`
`obvious over Aart in view of the ‘333 publication.
`
`Claims 1, 2, 4, and 5 are unpatentable under 35 U.S.C. § 103(a) as
`
`obvious over the ‘415 publication in view of the ‘510 publication or the
`
`‘941 patent.
`
`Exhibit 1003, page 8
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`Claims 2 and 12 are unpatentable under 35 U.S.C. § 103(a) as obvious
`
`over the ‘333 publication in view of the ‘941 patent.
`
`Claims 4 and 14 are unpatentable under 35 U.S.C. § 103(a) as obvious
`
`over the ‘333 publication in view of the ‘415 publication, the ‘530
`
`publication, or the ‘183 publication.
`
`Claims 1, 5, 11, and 15 are unpatenable under 35 U.S.C.
`§ 102(b) as anticipated by the ‘333 publication, or under 35
`U.S.C. § 103(a) as obvious over the ‘333 publication, alone or
`in combination with Aart or the ‘474 patent
`
`1.
`
`Claims 1, 5, 11, and 15 are unpatenable under 35 U.S.C.
`§ 102(b) as anticipated by the ‘333 publication
`
`The ‘333 publication was published on September 21, 1993, more than one year
`
`before the earliest U.S. priority date of the application for the ‘48O patent, and is thus
`
`prior art to the ‘48O patent under 35 U.S.C. § 102(b). The ‘333 publication relates to the
`
`contact portion from an active matrix liquid crystal display (LCD) device. Figure 7(a)
`
`from the ‘333 publication, which is reproduced below, shows a cross-sectional view of a
`
`terminal part of an LCD device:
`
`Exhibit 1003, page 9
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`This figure shows a contact structure interposed between a TFT substrate
`
`(substrate 14) and another substrate from a peripheral circuit (base film 20). The
`
`contact structure includes at least an underlying metal layer 1, an insulating layer 5, an
`
`overlay metal layer 3, a transparent metal layer 4, metal particles 16, and copper plating
`
`pattern 21. The insulating layer 5 has a plurality of openings 2 in it. The underlying
`
`metal layer 1
`
`is connected to overlay metal layer 3 and transparent metal layer 4 in the
`
`openings 2. The metal particles 16 are dispersed such that some of them are located
`
`over the insulating layer 5 and in contact with overlay metal layer 3, transparent metal
`
`layer 4, and copper plating pattern 21.
`
`Figure 5 from the ‘333 publication, which is reproduced below, shows a cross
`
`section from a different portion of an LCD device, along the line D-D’ shown in Figure 4,
`
`reproduced below:
`
`([215)
`
`I
`
`I6
`
`£2
`Ilzrex-I-121.91.:
`
`'9
`
`Exhibit 1003, page 10
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`instead of showing a contact structure interposed between a TFT substrate and a
`
`substrate from a peripheral circuit, Figure 5 shows a contact structure between a TFT
`
`substrate and a substrate other than one from a peripheral circuit, such as a common
`
`substrate (both substrates in Figure 5 are depicted as substrate 14). Although copper
`
`plating pattern 21 does not contact metal particles 16, opposing electrode 17 does.
`
`One of ordinary skill in the art would appreciate that if Figure 5 was a cross-section
`
`along a line extending at a 45 degree angle with respect to line D-D’, that the resulting
`
`figure would look similar to Figure 7(a). There would be an underlying metal layer 1
`
`connected to an overlay metal layer 3 and transparent metal layer 4 in openings 2,
`
`which are located in an insulating layer 5. Some of metal particles 16 would be located
`
`over the insulating layer 5 and in contact with overlay metal layer 3, transparent metal
`
`layer 4, and opposing electrode 17.
`
`Exhibit 1003, page 11
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`The following claim chart demonstrates how the ‘333 publication anticipates
`
`claims 1, 5, 11, and 15 of the ‘480 patent:
`
`Claims of U.S. Patent No.
`6,404,480
`
`Exemplary Citations to
`JP 05-243333
`
`1. An active matrix display device
`comprising:
`
`“The present invention relates to thin-film field transistor-drive
`liquid crystal display devices." (paragraph 0001)
`
`a first substrate;
`
`“14 is a glass substrate" (paragraph 0004).
`
`a first interlayer insulating film
`provided over said first substrate;
`
`a first conductive film provided on
`said first interlayer insulating film;
`
`a second interlayer insulating film
`provided on said first conductive
`film, said second interlayer insulating
`film having at least two openings;
`
`a second conductive film provide on
`said second interlayer insulating film
`and in said openings;
`
`inherently formed over or integrated to substrate 14'.
`
`“First a terminal part underlying metal layer 1, scan lines 6,
`and gate electrodes 7, made from a 2000 angstrom—thick
`chrome layer, are fabricated on a glass substrate 14."
`(paragraph 0006)
`
`“5 is an insulating layer, 2 is a contact hole in the insulating
`layer" (paragraph 0014)
`
`"3 is an overlay metal layer, 4 is a transparent metal layer”
`(paragraph 0014)
`
`1 An Office Action dated December 29, 2005 (copy attached as Exhibit L) issued in U.S. Application No.
`10/125,394, a divisional application of the ‘480 patent, used the ‘333 publication in a § 102 rejection of
`most of the claims. The independent claims from that application are nearly identical to the independent
`claims of the ‘480 patent (copy of the claims from U.S. Application No. 10/125,394 attached as Exhibit M).
`Also in the Office Action, the Examiner found a first interlayer insulating film inherent in the ‘333
`publication.
`
`-10-
`
`Exhibit 1003, page 12
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`Claims of U.S. Patent No.
`6,404,480
`
`a second substrate opposed to said
`first substrate;
`
`a third conductive film provided on
`said second substrate; and
`
`a plurality of conductive spacers
`held between said first substrate and
`said second substrate;
`
`wherein said first conductive film is
`connected with said second
`
`conductive film in said openings;
`
`wherein at least one of said
`conductive spacers is held over said
`second interlayer insulating film and
`in contact with both said second
`conductive film and said third
`conductive film.
`
`5. An active matrix display device
`according to claim 1, wherein said
`active matrix display device is a
`liquid crystal display device.
`
`Exemplary Citations to
`JP 05-243333
`
`"The connections to the external circuits are made by placing
`a base film 20, on which a copper plating pattern 21 is
`fabricated, on a specific location with a thermal curable resin
`22, which contains metal particles 16, interposed between
`[said copper plating pattern 21 and] the transparent metal
`layer 4." (paragraph 0007)
`
`"Figure 5 shows a cross-sectional drawing along the section
`D-D’ in the contact terminal part with the opposing substrate
`in Figure 4.” (paragraph 0020)
`
`“The connections to the external circuits are made by placing
`a base film 20, on which a copper plating pattern 21 is
`fabricated, on a specific location with a thermal curable resin
`22, which contains metal particles 16, interposed between
`[said copper plating pattern 21 and] the transparent metal
`layer 4." (paragraph 0007)
`
`"17 is an opposing electrode made from a transparent metal”
`(paragraph 0020)
`
`“The connections to the external circuits are made by placing
`a base film 20, on which a copper plating pattern 21 is
`fabricated, on a specific location with a thermal curable resin
`22, which contains metal particles 16, interposed between
`[said copper plating pattern 21 and] the transparent metal
`layer 4." (paragraph 0007)
`
`The underlying metal layer 1 is connected with the
`transparent metal layer 4 and/or overlay metal layer 3 in the
`contact holes 2. (See e.g., Figure 7(a))
`
`The metal particles 16 are held over the insulating layer 5
`and in contact with the transparent metal layer 4 and/or
`overlay metal layer 3, and the copper plating pattern 21. (See
`e.g., Figure 7(a))
`
`“The present invention relates to thin-film field transistor-drive
`liquid crystal display devices.” (paragraph 0001)
`
`11. An active matrix display device
`comprising:
`
`“The present invention relates to thin-film field transistor-drive
`liquid crystal display devices.” (paragraph 0001)
`
`Exhibit 1003, page 13
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`Claims of U.S. Patent No.
`6,404,480
`
`Exemplary Citations to
`JP 05-243333
`
`a first substrate;
`
`“14 is a glass substrate” (paragraph 0004).
`
`a first interlayer insulating film
`provided over said first substrate;
`
`a first conductive film provided on
`said first interlayer insulating film;
`
`a second interlayer insulating film
`provided on said first conductive
`film, said second interlayer insulating
`film having at least two openings;
`
`a second conductive film provided
`on said second interlayer insulating
`film and in said openings;
`
`a second substrate opposed to said
`first substrate;
`
`a third conductive film provided on
`said second substrate; and
`
`inherently formed over or integrated to substrate 14.
`
`“First a terminal part underlying metal layer 1, scan lines 6,
`and gate electrodes 7, made from a 2000 angstrom-thick
`chrome layer, are fabricated on a glass substrate 14.”
`(paragraph 0006)
`
`"5 is an insulating layer, 2 is a contact hole in the insulating
`layer’ (paragraph 0014)
`
`"3 is an overlay metal layer, 4 is a transparent metal layer’
`(paragraph 0014)
`
`"The connections to the external circuits are made by placing
`a base film 20, on which a copper plating pattern 21 is
`fabricated, on a specific location with a thermal curable resin
`22, which contains metal particles 16, interposed between
`[said copper plating pattern 21 and] the transparent metal
`layer 4.” (paragraph 0007)
`
`“Figure 5 shows a cross-sectional drawing along the section
`D-D’ in the contact terminal part with the opposing substrate
`in Figure 4.” (paragraph 0020)
`
`“The connections to the external circuits are made by placing
`a base film 20, on which a copper plating pattern 21 is
`fabricated, on a specific location with a thermal curable resin
`22, which contains metal particles 16, interposed between
`[said copper plating pattern 21 and] the transparent metal
`layer 4.” (paragraph 0007)
`
`“1 7 is an opposing electrode made from a transparent metal”
`(paragraph 0020)
`
`Exhibit 1003, page 14
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. O9325.0013
`
`Claims of U.S. Patent No.
`6,404,480
`
`Exemplary Citations to
`JP 05-243333
`
`a plurality of conductive spacers
`held between said first substrate and
`said second substrate;
`
`wherein said first conductive film is
`connected with said second
`conductive film in said openings;
`
`wherein at least one of said
`conductive spacers is held over said
`second interlayer insulating film and
`in contact with both said second
`conductive film and said third
`conductive film;
`
`wherein each of said openings
`occupies an area larger than an area
`occupied by each of said conductive
`spacers.
`
`15. An active matrix display device
`according to claim 11, wherein said
`active matrix display device is a
`liquid crystal display device.
`
`“The connections to the external circuits are made by placing
`a base film 20, on which a copper plating pattern 21 is
`fabricated, on a specific location with a thermal curable resin
`22, which contains metal particles 16, interposed between
`[said copper plating pattern 21 and] the transparent metal
`layer 4." (paragraph 0007)
`
`is connected with the
`The underlying metal layer 1
`transparent metal layer 4 and/or overlay metal layer 3 in the
`contact holes 2. (See e.g., Figure 7(a))
`
`The metal particles 16 are held over the insulating layer 5
`and in contact with the transparent metal layer 4 and/or
`overlay metal layer 3, and the copper plating pattern 21. (See
`e.g., Figure 7(a))
`
`Each contact hole 2 occupies an area larger than an area
`occupied by a metal particle 16. (See e.g., Figure 7(a))
`
`“The present invention relates to thin-film field transistor—drive
`liquid crystal display devices.” (paragraph 0001)
`
`Claims 1, 5, 11, and 15 are unpatentable under 35 U.S.C.
`§ 103(a) as obvious over the ‘333 publication, alone or in
`combination with Aart or the ‘474 patent.
`
`Even if a first interlayer insulating film is not inherent in the ‘333 publication, it
`
`would have been obvious to have such a film. The ‘333 publication indicates that the
`
`particular structure of the TFTs does not matter (see, e.g., paragraph 0022). Because
`
`the number of insulating layers is dictated by the type of TFT, one of ordinary skill in the
`
`art would be motivated to use a first interlayer insulating film in the system of the ‘333
`
`publication when switching to a TFT that would improve performance of the LCD device
`
`Exhibit 1003, page 15
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`(e.g., switching to a faster TFT, etc.) Many TFTs, such as poly-Si TFTs, which are
`
`faster than amorphous TFTs, typically have structures that require at least a first and
`
`second interlayer insulating film.
`
`Moreover, the ‘474 patent and Aart each provide an example of LCD devices that
`
`include a first interlayer insulating film. For example, the ‘474 patent shows a first
`
`interlayer insulating film in Fig. 12 (gate insulating film 37), which has been reproduced
`
`in the claim chart in section D below. Additionally, Aart shows a first interlayer
`
`insulating film in Fig. 13 of the ‘48O patent (see e.g., the unlabeled gate insulating film
`
`between internal conducting lines 21 and substrate 11), which is part of the admitted
`
`prior art and has been reproduced in the claim chart in section F below.
`
`It would have been obvious to one of ordinary skill in the art to incorporate the
`
`first interlayer insulating film from the ‘474 patent or Aart into the system of the ‘333
`
`publication because the ‘333 publication indicates that the particular structure of its
`
`TFTs does not matter. Switching TFT types from the kind shown in the ‘333 publication
`
`to one of the kinds shown in the ‘474 patent or Aart may put the TFT substrate of the
`
`LCD device in the ‘333 publication more in line with most TFT substrates, which include
`
`both a first and second insulating layer. Another insulating layer, for example, may
`
`provide increased protection from damage.
`
`Accordingly, since the ‘333 publication discloses each of the other features of
`
`claims 1, 5, 11, and 15 other than the first insulating layer, and the prior art would have
`
`new question of patentability differs from
`because in section F, Aart is used as the
`
`-14-
`
`Exhibit 1003, page 16
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. O9325.0013
`
`motivated a person of ordinary skill to include such a layer, the claims would have been
`
`obvious even if the existence of such a layer was not inherent in the ‘333 publication.
`
`C.
`
`Claims 1, 2, 5, 11, 12, and 15 are unpatentable under 35 U.S.C.
`§ 102(e) as anticipated by the ‘456 patent
`
`The ‘456 patent issued on May 26, 1998, which is after the earliest priority date
`
`of the ‘480 patent, March, 27, 1997, but since it was filed on March 8, 1996, it is thus
`
`prior art to the ‘480 patent under 35 U.S.C. § 102(e). Moreover, the ‘745 publication
`
`and the ‘686 publication, from which the ‘456 patent claims priority, were published on
`
`September 27, 1996, and October 10, 1996, respectively, and are prior art to the ‘480
`
`patent under 35 U.S.C. § 102(b).
`
`The ‘456 patent relates to the contact portion between two substrates associated
`
`with an active matrix liquid crystal display (LCD) device. Figure 5A from the ‘456 patent,
`
`reproduced below, includes annotations facilitating an explanation of certain features
`
`disclosed in the ‘456 patent.
`
`nuuuj
`\\\\\\\\>\\“\\‘\".‘\\§k\\\\\_\.\\\\\\\\\\\\\>\;...:
`§‘
`V/IA
`
`'
`
`Annotated Figure 5A shows a contact structure interposed between a first
`
`substrate (31) and a second substrate (49). The contact structure includes at least an
`
`interlayer dielectric film 41, output terminal lines 44, a silicon nitride film 46, an ITO
`
`-15-
`
`Exhibit 1003, page 17
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`electrode 47, gold bumps 48, and an electrode 50. The output terminal lines 44 are
`
`connected to ITO electrode 47 in openings present in the silicon nitride film 46. The
`
`gold bumps 48, which may be replaced by conductive particles, are dispersed such that
`
`at least some of them are located over the silicon nitride film 46 and in contact with ITO
`
`electrode 47 and electrode 50.
`
`The following claim chart demonstrates how the ‘456 patent anticipates claims 1,
`
`2, 5, 11, 12, and 15 of the ‘480 patent.
`
`Claims of U.S. Patent No.
`5'4°4’48°
`1. An active matrix display device
`comprising:
`
`Exemplary Citations to
`u.s. Patent No. 5,757,456! JP os-25o745/
`JP 08-2546863
`
`“the invention can be similarly applied to an active matrix
`display." (col. 5, lines 55-56.)
`
`a first substrate;
`
`glass substrate 31
`
`a first interlayer insulating film
`provided over said first substrate;
`
`T
`N‘-"U".\\‘i"“'"§‘j'l
`V/4./4/%%:W//r/% wr//4'//zji
`T —
`wmmmumnvumrmmummmmummnununrulmunmmiuumuummminunmrmmmuunnn1
`T
`39
`40
`3.
`
`a first conductive film provided on
`said first interlayer insulating film;
`
`output terminal lines 44
`
`_j_j__
`
`3 Citations are to U.S. Patent No. 5,757,456.
`
`-16-
`
`Exhibit 1003, page 18
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. 09325.0013
`
`Claims of U.S. Patent No.
`6,404,480
`
`Exemplary Citations to
`U.S. Patent No. 5,757,456] JP 08-250745!
`JP 08-2546863
`
`a second interlayer insulating film
`provided on said first conductive
`film, said second interlayer insulating
`film having at least two openings;
`
`“A silicon nitride film 46 having a thickness of 2000 .ANG.
`was deposited as a passivation film on the laminate by
`plasma CVD. Contact holes communicating with the output
`terminal lines 44 were formed in this passivation film.” (col. 7,
`lines 19-22.)
`
`L\\\\\§\\\\V\\wVm\§\\\\\\
`
` WflflHlllflM MWMflmlMflWWMH lflMMWmlMmflIflNM
`
`Figure 4C
`
`a second conductive film provide on
`said second interlayer insulating film
`and in said openings;
`
`ITO electrode 47
`
`a second substrate opposed to said
`first substrate;
`
`substrate 49
`
`.\\“\\\\}““\“\\‘}‘}\_\\\\\\-‘\“‘\‘\\\\\\}\‘.—&\‘\§K\\\‘
`“‘?a‘-"'IE|i\‘-U-‘~s-'w‘I4"'S‘-j
`%%— '
`mU IWM HDMI Wfl
`
`Figure 5A
`
`a third conductive film provided on
`said second substrate; and
`
`electrode 50
`
`a plurality of conductive spacers
`held between said first substrate and
`said second substrate;
`
`Gold bumps 48 are held between substrate 31 and substrate
`49 (see FIGS. 4C and 5A).
`
`Moreover, the “contact portion can use a bump as described
`above. Another method is illustrated in Figure 1(D). That is,
`conductive particles 9 such as particles of gold are diffused
`into the contact portion to provide electrical contact.” (col. 5,
`lines 12-16).
`
`.\\\\\\\s\\\\\\\\\\m\\\\m\\\\v
`__.____
`l’%lanexa.vr%-W‘-"*1
`
`Figure 1 D
`
`Exhibit 1003, page 19
`
`

`
`Request for Reexamination of U.S. Patent No. 6,404,480
`Customer No. 22,852
`Attorney Docket No. O9325.0013
`
`Claims of U.S. Patent No.
`6,404,480
`
`wherein said first conductive film is
`connected with said second
`conductive film in said openings;
`
`wherein at least one of said
`conductive spacers is held over said
`second interlayer insulating film and
`in contact with both said second
`conductive film and said third
`conductive film.
`
`Exemplary Citations to
`u.s. Patent No. 5,757,456/ JP 08-250745/
`JP 08-2546863
`
`output terminal lines 44 are connected to ITO electrode 47 in
`the openings. (see FIGS. 4C, 5A.)
`
`Figure 5A shows that gold bumps 48, which can be replaced
`by conductive particles 9, are held over silicon nitride film 46
`and in contact with both ITO electrode 47 and electrode 50.
`
`\‘
`\ \\ - \\
`J—ET'm¢wf