Trials@uspto.gov
`Tel: 571-272-7822
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`
`
`
`
`
`Paper 48
`Entered: 2 January 2014
`
`RECORD OF ORAL HEARING
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`XILINX, INC.
`Petitioner
`
`
`
`
`
`
`v.
`
`
`INTELLECTUAL VENTURES I LLC
`Patent Owner
`
`________________
`
`
`
`Case IPR2013-00029
`Patent 5,632,545
`_________________
`
`Oral Hearing Held December 9, 2013
`
`
`
`Before SALLY C. MEDLEY, KARL D. EASTHOM, and JUSTIN T. ARBES,
`Administrative Patent Judges.
`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`DAVID L. McCOMBS
`
`
`THOMAS B. KING
`
`
`Haynes and Boone, LLP
`
`ON BEHALF OF THE PATENT OWNER:
`GEORGE E. QUILLIN
`Foley & Lardner, LLP
`
`
`
`
`
`
`
`
`
`
`
`
`Tel: 571-272-7822
`
`
`
`
`
`
`Paper 48
`Entered: 2 January 2014
`
`RECORD OF ORAL HEARING
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`XILINX, INC.
`Petitioner
`
`
`
`
`
`
`v.
`
`
`INTELLECTUAL VENTURES I LLC
`Patent Owner
`
`________________
`
`
`
`Case IPR2013-00029
`Patent 5,632,545
`_________________
`
`Oral Hearing Held December 9, 2013
`
`
`
`Before SALLY C. MEDLEY, KARL D. EASTHOM, and JUSTIN T. ARBES,
`Administrative Patent Judges.
`
`
`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`DAVID L. McCOMBS
`
`
`THOMAS B. KING
`
`
`Haynes and Boone, LLP
`
`ON BEHALF OF THE PATENT OWNER:
`GEORGE E. QUILLIN
`Foley & Lardner, LLP
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`P R O C E E D I N G S
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`JUDGE MEDLEY: Good morning. This is the hearing
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`for IPR2013-00029 between Petitioner Xilinx and Patent Owner
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`Intellectual Ventures.
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`At this time, we would like the parties to please
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`introduce themselves starting with the Petitioner.
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`MR. MCCOMBS: Good morning, Your Honors. I'm
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`David McCombs, from Haynes and Boone on behalf of Petitioner
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`Xilinx, and with me is Thomas King, also with Xilinx. And
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`Tom will be giving the presentation today.
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`JUDGE MEDLEY: Okay.
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`MR. QUILLIN: George Quillin, Your Honor, for
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`Foley and Lardner on behalf of the patent owners,
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`Intellectual Ventures.
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`With me at the table is my partner, Paul Hunter,
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`and behind me are representatives, in-house counsel from
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`Intellectual Ventures, Ms. Jeanne Suchodolski and Mr. Don
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`Coulman.
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`JUDGE MEDLEY: Okay. Thank you.
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`Per the hearing order, each party has 60 minutes
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`total time. Petitioner, you'll begin with your presentation
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`of your case and then you reserve rebuttal. And then, with
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`respect to your challenged claims, on which the basis for
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`which you institute a challenge, and then the Patent Owner,
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`you'll respond to Petitioner's case, and you'll also present
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`your case on your motion to amend.
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`And then Petitioner, you can take the rest of
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`your time to respond to Patent Owner's presentation on all
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`issues. And then, lastly, Patent Owner, you just have
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`rebuttal time with respect to your motion to amend. Okay?
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`Petitioner, you may begin.
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`How much time would you like to reserve for
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`rebuttal?
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`MR. KING: I would like to reserve 20 minutes for
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`rebuttal.
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`JUDGE MEDLEY: Okay. You have 40 minutes right
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`now. My clock says 9:43. Okay.
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`(Whereupon, there was a pause in the
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`proceedings.)
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`MR. KING: May I begin?
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`JUDGE MEDLEY: Yes.
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`MR. KING: Good morning.
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`As Mr. McCombs said, my name is Tom King, from
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`Haynes and Boone, and I will be presenting Petitioner
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`Xilinx's in argument today on behalf of -- on why the Board
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`should find that the claims of the '545 Patent are obvious.
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`Just as an overview of what the topics I will be
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`covering today, I want to go through it quick.
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`It's a little bit out of order here, but I do
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`want to go through a quick technical orientation on what this
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`-- what the claim at issue is and what the main prior art
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`reference and the last prior art reference teaches.
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`Then I want to address obviousness under the
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`Board's constructions.
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`We believe under the constructions the Board
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`adopted in its decision to institute, that there are only two
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`remaining issues that IV has raised that need to be decided.
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`One is whether the Flasck reference runs at video speeds and
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`the other is whether the Flasck reference teaches a video
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`controller.
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`After that, I want to go to obviousness in view
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`of Takanashi. And then, if time remains, I'll return to why
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`the -- why the '545 patent claims are obvious, even if the
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`Board were to adopt IV's constructions.
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`So that's the -- in general, that's the order
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`we'll go in today. I'm happy to answer whatever questions
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`the Board has on other topics, but this is what I expect to
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`do.
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`We have here on the form board, and I'll put it
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`up on video, on the Elmo as well, a demonstrative that shows
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`the claims of the '545 patent and how they map up to the
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`Flasck reference.
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`The Flasck reference -- sorry, the claims of the
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`'545 patent teach a number of components that are arranged to
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`allow light beams to create a projected image, much like the
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`projected image that we see here on the Elmo.
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`It starts with three individual light sources.
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`And those light sources create or pass through a lens system,
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`and then they're passed through color filters to create what
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`are typically red, green and blue light beams. These light
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`beams then pass through a set of light-shutter matrices which
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`encode the red, the green and the blue channels onto those
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`light beams. So the red portion of the image we see here
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`would go through one light-shutter matrix. The blue portion
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`and the green portion would each have their own separate
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`light-shutter matrix.
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`Then there is an optical combination system that
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`combines the various channels together to create an image --
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`to create a light beam that is encoded and ready to be
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`projected onto a display.
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`This was not a new system when the '545 patent
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`was filed. In fact, the record shows a numbers of systems
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`that took -- that divided light beams into -- or that took
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`multiple light beams, shined them, created and made
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`monochrome-colored light beams, shined them through LCDs or
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`other types of light-shutter matrices and then recombined
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`them for projection.
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`Now, we've seen several of these in the record.
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`The two that are at issue is the primary reference of Flasck
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`and Takanashi. But this is simply -- that core idea was not
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`new in 1996.
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`What is at issue today is whether this specific
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`combination of elements would have been obvious to a person
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`of skill in the art, and we believe that it was.
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`On the bottom of this demonstrative you can see
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`the Flasck reference, Figure 11 and Figure 2C from the
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`Flasck.
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`Figure 11 starts with -- just for example on the
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`blue, it start with a light source. That light source then
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`passes through -- it's a slightly different order than what's
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`claimed, but there is a lens system, here, in the reflected
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`image claim module. There is also a color filter, here, 124.
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`There's a light-shutter matrix system that's within these
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`boxes. Figure 2C is what's within the green, the red and the
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`blue boxes. The light-shutter matrix system is here. The
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`optical combination system is marked in red. And then the
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`last element or -- I'm sorry, element G is where in each a
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`beam passes through a color filter before passing -- being
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`processed by a light-switching matrix where you can see that
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`the color filter here is here. I will mark that as C, F and
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`the light-switching matrix is here, so that element is met as
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`well.
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`Now, there is an issue with the -- that we'll
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`address today with regards to the video controller. This
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`system refers to an interface 118 and the Board found in its
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`preliminary -- or in its decision to institute that was
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`not -- that being connected to the light-shutter matrix
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`system wasn't enough to provide control.
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`We believe that the evidence in the Flasck patent
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`shows that that interface does in fact provide control or at
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`the very least a person of skill in the art will understand
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`that something within the interface was providing the light
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`encoding information that goes to -- that goes to and
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`controls the light-shutter matrix system.
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`So that's a quick orientation on what the Flasck
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`reference teaches.
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`And under the Board's construction, like I said,
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`we believe there are only two issues that remain to be
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`decided, one of which is whether the Flasck reference runs at
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`video speeds.
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`Now, the Flasck reference teaches that its
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`light-shutter matrix systems are created out of a technology
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`called PDLC. That's polymer disbursed liquid crystal.
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`That's a type of liquid crystal where the liquid crystal is
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`combined with the polymer.
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`And IV pointed to a reference or pointed to
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`evidence that they said showed that PDLC technology was too
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`slow in 1996 to be used with a projection system. And in
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`particular they pointed to the Lackner patent, Exhibit 2000
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`-- 2011, and they argued that the combined on/off response
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`time of a PDLC system at the time of Flasck was at least one
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`and a half seconds, which is significantly slower than the
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`response time required for video.
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`That refers to the switching speed of the liquid
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`crystal. The liquid crystal actually switched it -- if PDLC
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`liquid crystal actually switched at one and a half seconds,
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`that would be too slow to project video like we have right
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`The problem was the Lackner reference doesn't
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`support this assertion.
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`So if you actually go to Exhibit 2011, the
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`Lackner patent, what you'll see is that it gives several
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`different examples of PDLC.
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`And the first example does, in fact, support --
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`supports IV's assertion, but the rest of them do not.
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`So it says in the Lackner patent that the
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`photoactivated -- that photoactivated is critical.
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`The photoactivated rise in the K-times were five
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`to ten milliseconds on time and one and a half to three
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`seconds off time.
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`Photoactivated is only one way of using PDLC.
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`Another way to use PDLC is to activate it with -- directly
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`with the voltage signal. And that's what Lackner teaches.
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`In the same example the voltage of the PDLC type
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`film to a square voltage post was much faster, with a rise in
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`the K-times of less than one millisecond and 15 milliseconds.
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`Now, we asked Mr. Smith-Gillespie, IV's expert
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`about Lackner and about that quote in particular. He said if
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`that were achievable on a matrix-type device, then it would
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`be possible to achieve acceptable response times.
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`He's backing off of what he said in his --
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`backing off what he said in his declaration. "I don't think
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`this is a matrix, but if it were a matrix, then it would be
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`fast enough."
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`Well, the problem is if you keep on reading
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`Lackner, Lackner teaches that PDLC systems were in fact used
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`in light shutter -- in projection systems. You may have seen
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`this in our -- you probably saw this in our reply briefing.
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`Lackner teaches a television, a full-color
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`projection television that was made using PDLC technology.
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`We think the fact -- this is only one example.
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`This is the third example on Lackner. The fourth example
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`also teaches the television. Not only does it teach the
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`television, it teaches an active-matrix display.
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`And so what we saw from both doctor -- or Mr.
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`Smith-Gillespie's deposition and from his declaration was
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`that his beliefs on PDLC, as informed by the Lackner patent,
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`were just -- weren't right. They weren't supported by what
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`Lackner actually said.
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`And when we asked him about this at his
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`deposition, he said -- we asked him, "In fact, it looks like
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`they made a full-color projection TV using PDLC technology,
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`right?"
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`"That's what it says."
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`"And that's not something you were aware of when
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`you were testifying about PDLC technology earlier today,
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`right?"
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`"Apparently not."
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`So we think the admissions from IV's expert and
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`the statements in the Lackner patent itself, you know,
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`dispose of and rebut IV's argument that Flasck was incapable
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`of running at video speeds.
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`JUDGE ARBES: I'm sorry. Counsel, I think we
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`understand your position on PDLC and the Flasck reference.
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`Do you disagree with the patent owner's
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`construction of the term they construed, video projector
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`system? Does the Petitioner disagree with that?
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`MR. KING: Well, it wasn't apparent to me that
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`they proposed a construction of a video projector system.
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`And so I'm not sure what -- if there were a construction, I
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`doubt we would agree with it. But when we looked through
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`there, when we looked through their papers, we didn't see a
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`specific construction that they proposed.
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`They also did not -- you know, video projector
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`system appears in the preamble. There is no argument that
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`the preamble is -- is limiting here.
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`So I guess, Your Honor, I'm not sure what
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`construction you're referring to.
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`JUDGE ARBES: Okay. In their briefing they
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`propose that the video projector system requires projection
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`of moving images that change fast enough to be undetectable
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`by the human eye.
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`I understand the Petitioner's position is that
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`the video projector systems does not need to be construed?
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`MR. KING: That's our position. I don't disagree
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`with that construction.
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`I think applying that construction in another
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`case could be difficult, but here we don't disagree what
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`construction.
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`JUDGE ARBES: All right. Thank you.
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`MR. KING: So, the next issue is, I think, the key
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`issue here, which is whether Flasck teaches the use of a
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`video controller.
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`And in that regard, I just want to walk through
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`the evidence within Flasck.
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`So, the first place I want to direct the Board's
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`attention to is to Figure 1 of -- let's get that right. This
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`is Figure 1 of Flasck. It shows a prior video projection
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`system that takes light, shines it through a lens system --
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`shines it through a light-shutter matrix system that's
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`controlled by this video drive circuitry and then it's shined
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`through another lens and projected on to the screen.
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`This is the system that Flasck was trying to
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`improve upon or trying to replace. This system had some --
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`had some -- needed some improvement in 1996.
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`And just for reference, because the issue is
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`really -- the issue here, I think, is really whether the
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`discussion of this box Video of 20, the issue is really
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`whether the discussion of this box Video 20 has teachings
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`that carry over to how a person of ordinary skill in the art
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`would understand Figure 11 of Flasck. And in particular, the
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`interface on Figure 11.
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`So, if you look at Flasck column four, lines 16
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`through 21, let's start with line 11, which has the video
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`drive circuit -- it says, "a video or a computer signal
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`source is coupled by a line to a video drive circuit."
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`We don't think there's any dispute that that
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`video drive circuit is a -- would be a video controller if
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`this Figure 1 had all of the other elements of the prior art
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`or all of the other elements claimed by the applied-for
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`patent.
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`So the video drive circuit operates on a signal
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`coupled thereto and generates the required drive signals over
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`a line 22 of the LCD. That's controlling.
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`And it's controlling because of what it says in
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`16. The drive signals cause the pixels of the LCD 16 to block
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`or transmit light to impart the required information onto the
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`light transmitted through the LCD.
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`Once again, that's controlling.
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`And I think the notion that LCD is, in part,
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`information to light is important because, as we'll see later
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`on, that's the same description that Flasck uses to describe
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`the system, not just the prior art system but the system that
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`it actually discloses as an invention.
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`So that's the prior art system that Flasck is
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`trying to improve upon.
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`Next, I want to draw the Board's attention to
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`Figure 9.
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`Now, our Petition focuses on Figure 11, which is
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`a slightly different -- has a different combination of
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`elements than Figure 9.
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`But figure 9 is still important because as we'll
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`see in a minute, the discussion of Figure 9 informs how a
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`person of skill in the art would understand Figure 11.
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`And you see down here at the bottom, TV or
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`computer face or computer interface electronics. And that's
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`marked as a 118.
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`The Flasck patent describes what this TV or
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`computer interface electronics does, and it does so on column
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`7, lines 32 through 34.
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`It says, "The information" -- start with 29 -- or
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`26 -- "a light beam passes through a mirror, 100, with only
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`the arcing from it therein." It was directed to a mirror and
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`reflected from the reflected image to a module.
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`The encoded light is reflected from the R
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`reflected image plane module.
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`That means light comes in, it's unencoded. When
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`it comes out of the image claim module, it has an image
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`encoded on it. And the information encoding is provided by
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`an electronic interface 118 coupled to the reflective image
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`plane modules.
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`That means, that's where we believe the control
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`is coming from. The interface is providing the information
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`that controls the reflective image plane module. In other
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`words, it changes the character of the liquid crystal
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`display, it imparts pixillation to the light.
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`JUDGE ARBES: Counsel, the encoding would just be
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`some pixels are turned on, some pixels are turned off; is
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`that right?
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`MR. KING: That's right.
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`Now, there's one more section I want to bring to
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`the Board's attention.
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`The Board will note that this section here is
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`actually talking about Figure 9. But we believe that also
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`applies to Figure 11. Not only because Figure 11 uses the
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`number 118, the same as Figure 9 to describe the interface,
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`but because on lines 38 through 40, it says -- it makes that
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`point explicit, I think. It says, "That the same are
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`equivalent elements of the projection system 120 and
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`succeeding systems utilize the same reference numerals as the
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`system 80." So that's why we think a person skilled in the
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`art reading this patent would understand the interface 118 is
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`controlling the light-shutter matrices or the
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`reflective-image plane modules of Flasck, and that's a video
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`controller.
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`This point was addressed during
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`Mr. Smith-Gillespie's IV's experts, deposition. I think this
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`really seals our point here.
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`We asked him, "Is it your testimony that any real
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`video projection system in 1996 would have had a video
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`controller?"
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`"Yes. That was my testimony yesterday, I think."
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`"Yes. And is that still your testimony today?"
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`"Yes."
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`So I'm not sure if this point is still disputed
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`by IV or not, but even if it is we think the evidence from
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`Flasck and the admissions from IV's expert require the Board
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`to find in our favor on this issue.
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`JUDGE ARBES: The question is not whether video
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`-- had a video controller, but whether any system would have
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`had a video controller adapted for controlling light-shutter
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`matrices. It doesn't seem that the -- that Mr.
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`Smith-Gillespie said that any system would have had that
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`particular type of video controller.
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`MR. KING: Okay. Let me address that issue for
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`you.
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`And if you'll forgive me for a minute, I have a
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`different set of slides on that.
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`So if you were to go back and read
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`Mr. Smith-Gillespie's deposition, what you'll see is after
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`that quote I put up there was a little bit of word parsing
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`where that very issue came up. And I asked -- he said,
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`"Well, not every video projection system would have a video
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`controller for controlling the light-shutter matrices." But
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`the reason he said that was he was thinking of video
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`controllers that didn't -- I'm sorry, video projection
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`systems that did not use light-shutter matrices at all. For
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`example, there are cathode-ray tube video projectors that
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`don't use -- that do not use that specific type of
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`technology. And so, I had to do a little bit more
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`cross-examination on that issue and if you forgive me, I can
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`find that very quickly.
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`(Whereupon, there was a pause in the
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`proceedings.)
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`MR. KING: So after this -- and I could -- we can
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`walk through the testimony in a little bit more detail, but I
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`think this answers your question. So, I asked him, "Okay.
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`So you're aware of video projection systems in 1996, right?"
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`"Yes."
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`"And you're aware of video projection systems
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`that used the matrix, active matrix LCDs in 1996, right?"
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`"Yes."
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`"Okay. And those video projection systems that
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`used active matrix LCDs in 1996, those systems would have had
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`some kind of module that controlled the light-shutter
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`matrices inside the system, right?"
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`He answered, "That's correct."
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`So, I think that's another way of saying -- of
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`making the same point that you just can't have a video
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`projection system that uses a light-shutter matrix without
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`some device that does the control.
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`And we believe that in the context of Flasck,
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`that device is either in the interface or it was part of the
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`interface. Of 118.
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`So, as I said before, we think the video speeds
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`and the video controller issues are the only issues under the
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`Board's -- under the construction the Board adopted in its
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`decision to institute. And the evidence that we've shown
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`requires a finding in our favor on obviousness, we believe.
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`On Claim 1. Claims 2 and 3 are -- I believe it's
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`undisputed that those claims rise and fall with Claim 1. And,
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`so, if the Board finds in our favor on those two issues and
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`on the construction that it adopted in its decision to
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`institute, then we believe the Board should find Claim 1 --
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`or all claims invalid as obvious under Flasck.
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`Now, unless there are any questions on that, I'm
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`going to move on to the Takanashi reference.
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`JUDGE MEDLEY: Actually you have until about
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`10:25, I think. You started at a quarter till and you wanted
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`to take 40 minutes, correct?
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`MR. KING: Yes.
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`JUDGE MEDLEY: Okay.
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`MR. KING: Thank you.
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`So this is the Takanashi reference. Let me get
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`this right.
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`The Takanashi reference in combination with the
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`Lee patent also invalidates the claims of the '545 patent.
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`Just as a quick technical report and orientation
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`of what's going on here, Takanashi starts off with one light
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`source. That's one of the reasons why it had to be combined
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`with another reference, because it only has one and the '545
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`patent requires individual light sources.
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`So light comes from the light source. It bounces
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`off a mirror system that divides it into separate light
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`beams. And then those light beams bounce off of these
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`spatial light modulators. These spatial light modulators are
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`devices that they're also liquid crystal devices that impart
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`image encoding information to the light beam. So the light
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`coming in is called a read light. And when is comes in it is
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`just a light beam. And when is bounces off of these image
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`plane modules, it achieves -- it's coded with image
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`information, which is then recombined in the same mirror
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`system for projection onto the display.
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`The biggest issue here on Takanashi is whether
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`these spatial light modulators qualify as light-shutter
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`matrices.
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`All right. IV argues that these spatial light
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`modulators are nothing more than continuous. They have
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`continuous elements of liquid crystal. And they distinguish
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`the Takanashi spatial light modulators from other technology
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`like active matrix LCDs.
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`We think that this distinction is more about
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`words than about substance.
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`So active matrix LCDs do not -- they have a
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`matrix, but the matrix, the physical matrix on an active
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`matrix LCD is for addressing. It is for addressing. It's for
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`creating -- the matrix is used as part of the process of
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`creating an image, creating a pixelated image. But the
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`matrix is not a light-shutter matrix. The light-shutter
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`matrix in an active matrix LCD comes from the -- it comes
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`from the active matrix portion of it. I'm not explaining that
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`well.
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`Let me try that again.
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`In any LCD, whether it's Takanashi or a standard
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`active matrix LCD, there is a continuous layer of liquid
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`crystal.
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`And that's what -- I think this is significant
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`that IV's expert admitted that "A liquid crystal layer is
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`often just a continuous layer across the entire display,
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`right?"
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`"That's correct."
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`In Takanashi, Takanashi -- both in Takanashi and
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`in active-matrix LCD, the light is encoded such that it has
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`pixels, all right. And the reason that it has pixels is
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`because something controls the liquid crystal to create
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`pixelated films. In an active matrix LCD, the control comes
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`from -- comes from the addressing matrix. So there is a
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`matrix of rows and columns that create pixels.
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`In Takanashi, Takanashi gives us something called
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`an optically addressed spatial light modulator. And in an
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`optically addressed spatial light modulator something else
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`provides the rows and columns. It's actually something calls
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`a write light. That write light typically comes from a
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`cathode-ray tube.
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`And it creates a pixelated -- it turns the liquid
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`crystal into a pixelated mass.
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`And so this example of -- this is an example not
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`from Takanashi but from another reference of a tri-colored
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`projection system that was a real world projection system
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`that had pixels. All right. You can see that it had a
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`vertical resolution and a horizontal resolution. And those
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`pixels, the fact that it has pixels means that there is a
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`light-shutter matrix. All right. The liquid crystal element
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`when a signal is applied to it, whether it's an electric
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`signal or whether it's an optical signal, that creates pixels
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`on the spatial light modulator and that fact makes -- turns
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`the liquid crystal element into -- into a light-shutter
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`matrix.
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`JUDGE ARBES: Counsel, there seems to be a
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`difference then with this write light arrangement -- the
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`matrix then is provided by that input, right? I mean, active
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`matrix LCD. The matrix is already there by virtue of the
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`structure, the liquid crystal and then the structure that
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`provide the direction. It doesn't require something outside
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`the device like it does with a write light, is that right?
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`MR. KING: That's right, but I would like to look
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`at it in a different -- I think you need to look at it in a
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`slightly different way.
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`If you were to just look at the liquid crystal
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`element in the system of Takanashi or an active matrix
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`display, it would be very similar. It would be continuous.
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`If it were turned off -- if the system were turned off, it
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`would be absolutely continuous. There would be no matrixing
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`at all within either one of those liquid crystal elements.
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`The liquid crystal elements require an outside
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`signal to turn them from just liquid crystal into a
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`light-shutter matrix. And in an active matrix display, that
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`outside signal comes from wiring that's positioned right next
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`to the liquid crystal element.
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`JUDGE ARBES: But that wiring is part of the LCD
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`device, right?
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`MR. KING: It's part of the device just as the
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`ripe light is part of the Takanashi device.
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`There is -- when they are turned off, yes, there
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`is a matrix in the active matrix system that you can look at.
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`There's a physical matrix there, but it's not a light-shutter
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`matrix. It's not a light-shutter matrix until it's turned
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`on, because the wiring isn't a light shutter. The wiring is
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`an addressing matrix. The light-shutter matrix doesn't
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`happen until -- in either system until the system is turned
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`on and some type of -- some type of electrical or optical
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`signal is applied to the system.
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`JUDGE ARBES: But the write light is analogous.
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`That's the input that provides the encoding write light as to
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`what image you want it to have. That's analogous to the
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`electrical signal that comes in that changes the image using
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`the wiring, right.
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`MR. KING: That's correct.
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`JUDGE ARBES: So the write light and the
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`electrical signal are both inputted into the system. There
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`seems to be a difference in some of it. In the activation,
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`there is the computer and the wiring is the physical
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`component of the device. Whereas, in the system of
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`Takanashi, there's just the input, the write light input.
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`What other physical components are there there that might be
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`analogous to the wiring?
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`MR. KING: We haven't presented any in this case,
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`but I don't think that -- I don't think that point is
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`material, because the addressing matrix is in the
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`light-shutter matrix. It is an addressing matrix.
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`JUDGE ARBES: Okay. I think I understand.
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`MR. KING: Okay.
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`(Whereupon, there was a pause in the
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`proceedings.)
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`MR. KING: So let me just put this back up.
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`My point is that when a write light is used with
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`the Takanashi system, that it turns the spatial light
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`modulator -- and turns the spatial light modulator into a
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`light-shutter matrix. That's -- just as the input from an
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`active -- from the addressing portion of an active matrix, it
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`turns the liquid crystal portion into an light-shutter
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`matrix.
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`JUDGE EASTHOM: So that the optical beam doesn't
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`eliminate a certain portion of the matrix, is that the point?
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`MR. KING: The way -- this wasn't really fleshed
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`out too much in the record, but the way it works is you have
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`a CRT that shines onto a phosphor screen. And then the
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`phosphor screen is what actually illuminates the
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`objectly-sensitive portion of the spatial light modulator.
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`And so the beam is -- the beam activates the
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`phosphor. And then the phosphor -- and the beam scans across
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`the phosphor, and then the phosphor holds that signal for a
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`little bit of time.
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`JUDGE EASTHOM: Oh, the scan is what creates the
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`matrix.
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`MR. KING: Yeah. Yeah, it's just a raster scan.
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`Very similar to how a -- to how an old CRT
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`television works.
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`JUDGE ARBES: Counsel, could Takanashi operate
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`without that sort of matrixing pixelation? It seems to me the
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`patent owner made the argument that it could be like film
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`where although the patent does disclose two-dimensional image
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`that it's not real pixelated. Is that plausible?
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`MR. KING: That's possible. But I don't think
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`that's how somebody reading Takanashi would read it.
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`I think they
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