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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________
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`XILINX, INC.
`Petitioner
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`v.
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`INTELLECTUAL VENTURES I LLC
`Patent Owner
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`__________________
`
`Case IPR2013-00029
`Patent 5,632,545
`____________________
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`
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`INTELLECTUAL VENTURES’ PATENT OWNER MOTION TO AMEND
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`4843-2989-0580.2
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`Table of Contents
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`INTRODUCTION ...........................................................................................1
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`CLAIM LISTING............................................................................................1
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`
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`
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`I.
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`II.
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`III. WRITTEN DESCRIPTION SUPPORT..........................................................3
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`IV. CLAIMS 4 AND 5 ARE PATENTABLY DISTINCT OVER THE
`ART .................................................................................................................7
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`CONCLUSION AND RELIEF REQUESTED............................................ 15
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`V.
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`
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`4843-2989-0580.2
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`i
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`Table of Authorities
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`
`
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`Cases
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`Idle Free v. Bergstrom, IPR2012-00027................................................................ 7-8
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`Regulations
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`37 C.F.R. § 42.121 ................................................................................................ 1, 3
`37 C.F.R. § 42.22 .......................................................................................................1
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`4843-2989-0580.2
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`ii
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`
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`INTRODUCTION
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`Patent owner Intellectual Ventures I LLC moves pursuant to 35 U.S.C. § 316
`
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`I.
`
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`and 37 C.F.R. § 42.121 to cancel Claim 2 and to substitute Claim 4 in its place,
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`contingent on Claim 2 being found unpatentable by the Board, and similarly to
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`cancel 3 and to substitute Claim 5 in its place, contingent on Claim 3 being found
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`unpatentable by the Board.
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`Patent owner submits that Claims 4 and 5 do not introduce new subject
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`matter and that each of Claims 4 and 5 is fully supported by the originally filed
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`specification of U.S. Patent No. 5,632,545 (“the ‘545 patent”) as discussed in the
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`written description support section below. Also, Claims 4 and 5 do not enlarge the
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`scope of the patent claims; each includes the subject matter of the claim for which
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`it substitutes. Patent owner submits that this motion fully complies with 37 C.F.R.
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`§§ 42.22 and 42.121.
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`II. CLAIM LISTING
`2. (Canceled)
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`3. (Canceled)
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`4. (Proposed substitute for Claim 2) The video projection projector system
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`of claim 1 wherein the light-shutter matrices are monochrome LCD arrays, and
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`wherein the video projector system further comprises:
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`4843-2989-0580.2
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`1
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`
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`a heat containment system, wherein the heat containment system comprises
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`
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`an enclosure that isolates components in the heat containment system from other
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`components of the video projector system, and wherein the heat containment
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`system includes:
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`
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`the individual light sources;
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`heat filter glass adapted to filter heat from the separate light beams as
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`the separate light beams pass through the heat filter glass and exit the heat
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`containment system; and
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`
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`a fan in communication with an outside environment, wherein the fan
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`is adapted to force heat generated by the individual light sources and heat filtered
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`by the heat filter glass into the outside environment;
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`a second controller adapted to control the individual light sources and the
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`fan; and
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`a control link adapted to connect the video controller to the second controller
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`to provide individualized variable control of each of the individual light sources.
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`5. (Proposed substitute for Claim 3) The video projector system of claim 1
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`wherein three light sources provide three beams, and red, green, and blue filters are
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`used to provide red, green, and blue beams to an LCD matrix system, and wherein
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`the video projector system further comprises:
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`4843-2989-0580.2
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`2
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`
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`a heat containment system, wherein the heat containment system comprises
`
`
`
`an enclosure that isolates components in the heat containment system from other
`
`components of the video projector system, and wherein the heat containment
`
`system includes:
`
`
`
`
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`the individual light sources;
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`heat filter glass adapted to filter heat from the separate light beams as
`
`the separate light beams pass through the heat filter glass and exit the heat
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`containment system; and
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`
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`a fan in communication with an outside environment, wherein the fan
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`is adapted to force heat generated by the individual light sources and heat filtered
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`by the heat filter glass into the outside environment;
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`a second controller adapted to control the individual light sources and the
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`fan; and
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`a control link adapted to connect the video controller to the second controller
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`to provide individualized variable control of each of the individual light sources.
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`III. WRITTEN DESCRIPTION SUPPORT
`Pursuant to 37 C.F.R. § 42.121(b)(1), “[a] motion to amend claims must …
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`set forth … [t]he support in the original disclosure of the patent for each claim that
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`is added or amended.” The original disclosure of the patent is included in Exhibit
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`4843-2989-0580.2
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`3
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`1008. With respect to claim construction, patent owner submits that the claim
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`elements should be construed in accordance with their plain and ordinary meaning.
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`Claim 4 requires “[t]he video projector system of claim 1 wherein the light-
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`shutter matrices are monochrome LCD arrays.” The element is supported in the
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`originally filed specification at least by page 3, line 28 – page 4, line 1 and page 4,
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`lines 16-18 (Ex. 1008 at 9 and 10), as well as original Claim 2. The change from
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`“projection” in granted Claim 2 to “projector” in Claim 4 merely corrects an
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`obvious typographical error without any change in scope.
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`Claim 5 requires “[t]he video projector system of claim 1 wherein three light
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`sources provide three beams, ….” The element is supported in the originally filed
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`specification at least by page 3, lines 29-30, page 4, lines 6-7 and 12-13, and
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`elements 132-134 of Fig. 1 (Ex. 1008 at 9, 10, and 18, respectively), as well as
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`original Claim 3.
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`Claim 5 also requires that “red, green, and blue filters are used to provide
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`red, green, and blue beams to an LCD matrix system.” The element is supported in
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`the originally filed specification at least by page 3, line 29 – page 4, line 1, page 4,
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`lines 12-15, and elements 112-114 and 117-119 of Fig. 1 (Ex. 1008 at 9, 10, and
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`18, respectively), as well as original Claim 3.
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`4843-2989-0580.2
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`4
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`
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`Claims 4 and 5 require “a heat containment system, wherein the heat
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`containment system comprises an enclosure that isolates components in the heat
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`containment system from other components of the video projector system.” This
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`element is supported at least by page 4, lines 8-13 (Ex. 1008 at 10) and element
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`131 of Fig. 1 (Ex. 1008 at 18). Page 4, lines 8-10 state that “[t]he lamps are
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`provided in a separate sub-unit 131, which acts as a heat containment system,
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`exchanging the heat via fan 136 to the outside, rather than in the box.” (Ex. 1008
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`at 10).
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`Claims 4 and 5 also require that the heat containment system includes “the
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`individual light sources.” Support for this element can be found at least at page 4,
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`lines 8-9, which states that “[t]he lamps are provided in a separate sub-unit 131,
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`which acts as a heat containment system.” (Ex. 1008 at 10). See also Fig. 1 as
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`filed, which illustrates the three lamps 132-134 within the heat containment system
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`(element 131). (Ex. 1008 at 18).
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`Claims 4 and 5 also require that the heat containment system includes “heat
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`filter glass adapted to filter heat from the separate light beams as the separate light
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`beams pass through the heat filter glass and exit the heat containment system.”
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`Support for this element can be found at least at page 4, lines 10-11, which states
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`“[l]ight leaves heat containment system 131 via heat filter glass 123.” (Ex. 1008 at
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`4843-2989-0580.2
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`5
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`10). See also, element 123 of Fig. 1, which illustrates the heat filter glass of the
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`heat containment system 131. (Ex. 1008 at 18).
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`Claims 4 and 5 also require that the heat containment system includes a “fan
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`in communication with an outside environment, wherein the fan is adapted to force
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`heat generated by the individual light sources and heat filtered by the heat filter
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`glass into the outside environment.” Support for this element can be found at least
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`at page 4, lines 6-10 (Ex. 1008 at 10) and element 136 of Fig. 1. (Ex. 1008 at 18).
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`Page 4, lines 6-10 (Ex. 1008 at 10) discloses “a fan 136 for cooling the light
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`sources” and that “separate sub-unit 131, which acts as a heat containment system,
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`exchang[es] the heat via fan 136 to the outside, rather than in the box.”
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`Claims 4 and 5 also require “a second controller adapted to control the
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`individual light sources and the fan.” Support for this element can be found at
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`least at page 4, lines 6-8 (Ex. 1008 at 10) and element 130 of Fig. 1 (Ex. 1008 at
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`18). Page 4, lines 6-8 (Ex. 1008 at 10) states that “[l]ight for the projector is
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`generated in this embodiment by three High Intensity Discharge (HID) lamps 132-
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`134, which are controlled by controller 130, which also controls a fan 136 for
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`cooling the light sources.”
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`Claims 4 and 5 further require “a control link adapted to connect the video
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`controller to the second controller to provide individualized variable control of
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`4843-2989-0580.2
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`6
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`each of the individual light sources.” Support for this element can be found at least
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`at page 5, lines 12-14 (Ex. 1008 at 11) and element 124 of Fig. 1 (Ex. 1008 at 18).
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`Page 5, lines 12-14 states that “[a] control link 124 is provided between controllers
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`122 and 130, and this link is used in some embodiments for some limited variable
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`control of light output from each of the three light sources individually.” (Ex.
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`1008 at 11).
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`The originally filed specification supports the combination of elements of
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`Claims 4 and 5 as well. See, e.g., Fig. 1 of the ‘545 patent, which illustrates a
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`system that includes a heat containment system (131) having the individual light
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`sources (132-134), heat filter glass (123), and a fan (136), a second controller
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`(130), and a control link (124) in addition to the elements recited in Claim 1 (i.e.,
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`individual light sources (132-134), a lens system (115), individual color filters
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`(112-114), a light-shutter matrix system (120), a video controller (122), and an
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`optical combination system (111)). (Ex. 1008 at 18).
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`IV. CLAIMS 4 and 5 ARE PATENTABLY DISTINCT OVER THE ART
`On page 6 of its decision on the Motion to Amend in Idle Free v. Bergstrom,
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`IPR2012-00027 (Paper 26), the Board stated that “[f]or each proposed substitute
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`claim, we expect a patent owner: (1) in all circumstances, to make a showing of
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`patentable distinction over the prior art.” As demonstrated by the declaration of
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`4843-2989-0580.2
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`7
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`Mr. Smith-Gillespie, Ex. 2005, an expert in the field, Ex. 2006, patent owner
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`submits that Claims 4 and 5 are patentably distinct over both the prior art of record
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`and the prior art known to patent owner. Pages 6-7 of the Idle Free decision
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`identify two additional scenarios in which a showing of patentable distinction is
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`required. Patent owner submits that scenario (2) does not apply because the
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`present motion requests a one for one claim substitution. With respect to scenario
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`(3), page 9 of the Idle Free decision states (emphasis added) that "if the substitute
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`claim is presented as patentable over prior art on the same basis that another
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`substitute claim on which it depends is patentable over prior art, then the patent
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`owner should provide meaningful reasons …." Claims 4 and 5 do not depend on
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`one another, rather both claims depend from Claim 1. Thus, patent owner submits
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`that scenario (3) also does not apply.
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`Claims 4 and 5 require, in part, a “heat containment system” that includes
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`“the individual light sources,” “heat filter glass,” and “a fan” that “force[s] heat …
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`into the outside environment.” U.S. Patent No. 5,108,172 to Flasck (“Flasck”) (Ex.
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`1002) was relied upon by the Petitioner as the basis for Challenge #2 in its petition.
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`At col. 4, lines 30-38, Flasck discusses prior art “transmissive projection systems”
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`and states (emphasis added):
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`4843-2989-0580.2
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`8
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`
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`These transmissive projection systems suffer from a number of
`problems. One significant problem is caused by the construction
`required by the LC material. The LCD panels include a polarizer on
`each side of the LC material, such as twisted nematic material, and are
`utilized as a shutter to absorb the light not to be transmitted. Both the
`polarizers and the LC material absorb light which generates heat,
`which is deleterious to the LCD panel.
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`Flasck thus discloses that “heat” is “deleterious to the LCD panel.” To help
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`reduce this deleterious effect, Flasck discloses with reference to its Fig. 16 that “[a]
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`light beam 176 is directed through an optional heat absorbing glass plate 178 to a
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`condenser lens or lens combination 180.” (Col. 8, lines 54-56). Figure 16 of
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`Flasck illustrates that the “optional heat absorbing glass plate 178” (col. 8, line 55)
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`receives a “light beam 176” (col. 8, line 54). The “optional heat absorbing glass
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`plate 178” presumably absorbs a portion of the heat generated by “light beam
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`176.” (Ex. 2005 at ¶ 53). However, Fig. 16 of Flasck illustrates that the “optional
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`heat absorbing glass plate 178” is not in any way isolated from the other elements
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`of the illustrated “projection system” (col. 8, lines 50-51). (Ex. 2005 at ¶ 53).
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`Thus, any heat absorbed by the “optional heat absorbing glass plate 178” remains
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`in the “projection system” and increases the overall temperature of the “projection
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`system.” (Ex. 2005 at ¶ 53).
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`4843-2989-0580.2
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`9
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`
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`Conversely, Claims 4 and 5 require a “heat containment system” that
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`“comprises an enclosure that isolates components in the heat containment system
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`from other components of the video projector system” such that generated heat can
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`be forced “into the outside environment” as opposed to remaining in the system as
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`in Flasck. (Ex. 2005 at ¶ 54). The embodiment of Claims 4 and 5 therefore
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`addresses the problem identified in Flasck that generated “heat” is “deleterious to
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`the LCD panel,” but does so in a way that differs from the solution disclosed in
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`Flasck. (Ex. 2005 at ¶ 54).
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`Flasck fails to disclose or suggest at least “a heat containment system” that
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`“comprises an enclosure that isolates components in the heat containment system
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`from other components of the video projector system,” that the “heat containment
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`system” includes “the individual light sources,” “heat filter glass,” and a “fan,” or
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`that “the fan is adapted to force heat generated by the individual light sources and
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`heat filtered by the heat filter glass into the outside environment,” as required by
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`Claims 4 and 5. (See Mr. Smith-Gillespie’s declaration, Ex. 2005, at ¶ 55).
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`The combination of U.S. Patent No. 5,264,951 to Takanashi (Ex. 1003) and
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`U.S. Patent No. 5,287,131 to Lee (Ex. 1004), which forms the basis for Petitioner’s
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`Challenge #3, also fails to disclose or suggest “a heat containment system,” as
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`claimed. Takanashi, which does not include the term “heat,” makes no mention of
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`4843-2989-0580.2
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`10
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`any problems associated with generated heat or solutions to such problems. (See
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`Mr. Smith-Gillespie’s declaration at ¶ 56). In its background section, Lee states
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`that “in the case of a conventional projection system, due to the close distance
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`between the sources 7 and the LC panels 4, 5 and 6, in order to raise the brightness,
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`a cooling device is needed because heat generated from the source 7 has an
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`influence over the LCD characteristics.” (Col. 1, lines 50-55). The system of Lee
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`purportedly eliminates the need for such a cooling device as discussed at col. 3,
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`line 67 – col. 4, line 7 of Lee, which is reproduced below:
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`In this system, since the LC panel is formed remote from the light
`source distinct from that of a conventional system, increasing
`considerably the light source intensity does not have an influence over
`the LC panel characteristic, resulting in good brightness. Further, the
`respective light source could be easily controlled and the respective
`color could be easily corrected. Also, a cooling device for cooling the
`LC panel is not necessary any more.
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`Thus, Lee recognizes that heat can influence LCD characteristics, resulting
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`in the need for a cooling device. (Ex. 2005 at ¶¶ 56-57). Lee’s solution is to form
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`the LC panel remote from the light source. However, in such an implementation,
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`all of the heat generated by the light source still remains in the system and raises
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`the overall system temperature. (Ex. 2005 at ¶ 57). The embodiment of Claims 4
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`4843-2989-0580.2
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`11
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`and 5 therefore addresses the problem identified in Lee that generated heat can
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`affect LCD characteristics, but does so in a way that differs from the solution
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`disclosed in Lee. (Ex. 2005 at ¶ 57). Lee fails to disclose or suggest a “heat
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`containment system,” as claimed. The remaining prior art of record and the prior
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`art known to patent owner also fails to disclose or suggest such elements. See also
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`paragraph 57 of Mr. Smith-Gillespie’s declaration, Ex. 2005, which states that “I
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`am not aware of any video projection prior art that discloses the ‘heat containment
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`system,’ as required by proposed Claims 4 and 5.”
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`Patent owner submits that the above-referenced elements from Claims 4 and
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`5 and indeed the subject matter as a whole of those claims (which includes the
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`elements of Claim 1) would not have been obvious to one of ordinary skill in the
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`art at the time that the ‘545 patent was filed. This is evidenced by the fact that
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`Flasck identifies the problem that generated “heat” is “deleterious to the LCD
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`panel,” but does not discuss or contemplate the solution recited in Claims 4 and 5.
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`Lee similarly fails to discuss or contemplate the solution recited in Claims 4 and 5
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`in which generated heat is actually removed from the system. Rather, as discussed
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`above, Flasck and Lee offer inferior solutions in which the heat remains in the
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`projection system. Patent owner submits that Claims 4 and 5 are patentably
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`distinct at least because of the required “heat containment system.” See also
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`4843-2989-0580.2
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`12
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`paragraph 58 of Mr. Smith-Gillespie’s declaration, Ex. 2005, which states with
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`respect to Flasck and Lee that “[s]uch disclosures do not render the claimed ‘heat
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`containment system’ of Claims 4 and 5 obvious to one of ordinary skill in the art at
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`the time of filing the ‘545 patent.”
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`Claims 4 and 5 also require “a second controller adapted to control the
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`individual light sources and the fan” and “a control link adapted to connect the
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`video controller to the second controller to provide individualized variable control
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`of each of the individual light sources.” The “individualized variable control of
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`each of the individual light sources” allows a given light source to be individually
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`powered on only when the given light source is needed as opposed to being
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`continuously powered when the projection system is on. (Ex. 2005 at ¶ 59). This
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`individual control results in less heat generation, in addition to lower power
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`consumption. (Ex. 2005 at ¶ 59).
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`As discussed above, Flasck notes that generated “heat” is “deleterious to the
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`LCD panel.” To combat this problem, Flasck discloses an “optional heat
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`absorbing glass plate 178” (col. 8, line 55) that receives a “light beam 176” (col. 8,
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`line 54), and that presumably absorbs a portion of the heat generated by “light
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`beam 176.” (Ex. 2005 at ¶ 60). Lee similarly discloses that “heat generated from
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`the source 7 has an influence over the LCD characteristics.” (Col. 1, lines 53-55).
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`4843-2989-0580.2
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`13
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`
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`Flasck and Lee, however, fail to disclose or suggest “a second controller” or “a
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`control link … to provide individualized variable control of each of the individual
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`light sources” generally or as a way to reduce the generated heat that is deleterious
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`to the LCD panel or that affects characteristics of the LCD panel. (Ex. 2005 at ¶
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`60). The remaining prior art of record and the prior art known to patent owner also
`
`fails to disclose or suggest such elements. See also paragraph 60 of Mr. Smith-
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`Gillespie’s declaration, Ex. 2005, which states that “I am not aware of any video
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`projection prior art that discloses the combination of a ‘second controller’ and ‘a
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`control link … to provide individualized variable control of each of the individual
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`light sources,’ as required by proposed Claims 4 and 5.”
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`The embodiment of Claims 4 and 5 therefore addresses the problems
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`identified in Flasck and Lee with respect to generated heat, but does so in a way
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`that differs from the solutions disclosed in Flasck and Lee. (Ex. 2005 at ¶ 61).
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`Patent owner submits that the “second controller” and “control link” of Claims 4
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`and 5, and indeed those claims as a whole, would not have been obvious to one of
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`ordinary skill in the art at the time that the ‘545 patent was filed. (Ex. 2005 at ¶
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`61). This is evidenced by the fact that Flasck and Lee identify problems caused by
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`generated heat, but do not discuss or contemplate using “individualized variable
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`control of each of the individual light sources” to mitigate the problem. (Ex. 2005
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`4843-2989-0580.2
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`14
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`
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
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`at ¶ 61). Patent owner submits that Claims 4 and 5 are patentably distinct from the
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`prior art at least because of the required combination of the “second controller” and
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`“control link.” See also paragraph 61 of Mr. Smith-Gillespie’s declaration, Ex.
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`2005, which states that “[b]ased on my understanding of the prior art at the time of
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`filing the ‘545 patent, I do not believe that the ‘second controller’ and ‘control
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`link’ as recited in proposed Claims 4 and 5 would have been obvious to one of
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`ordinary skill in the art.”
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`For at least these reasons, patent owner submits that Claims 4 and 5 are
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`patentably distinct over the prior art.
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`V. CONCLUSION AND RELIEF REQUESTED
`If Claim 2 is found unpatentable, the Board should grant this motion and
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`find Claim 4 patentable. If Claim 3 is found unpatentable, the Board should grant
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`this motion and find Claim 5 patentable.
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`Dated: June 26, 2013
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`Respectfully submitted,
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`/George E. Quillin/
`George E. Quillin
`Registration No. 32,792
`Counsel for Patent Owner
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`4843-2989-0580.2
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`15
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`
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
`
`
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`LIST OF EXHIBITS
`
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`Exhibit 1002:
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`U.S. Patent No. 5,108,172 to Flasck
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`Exhibit 1003:
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`U.S. Patent No. 5,264,951 to Takanashi
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`Exhibit 1004:
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`U.S. Patent No. 5,287,131 to Lee
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`Exhibit 1008:
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`File history of U.S. Patent No. 5,632,545 to Kikinis
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`Exhibit 2005:
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`Declaration of Robert Smith-Gillespie
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`Exhibit 2006:
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`CV of Robert Smith-Gillespie
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`4843-2989-0580.2
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`16
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`Patent Owner Motion to Amend IPR2013-00029
`U.S. Patent No. 5,632,545
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that a copy of the foregoing Patent Owner Motion
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`to Amend and Exhibits 2005 -2006 along with an Exhibit List are being served on
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`counsel of record by filing these documents through the Patent Review Processing
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`System as well as delivering a copy via commercial overnight courier directed to
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`the counsel of record for the Petitioner at the following address:
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`David L. McCombs, Esq.
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
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`Respectfully submitted,
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`/George E. Quillin/
`George E. Quillin
`Registration No. 32,792
`Counsel for Patent Owner
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`Dated: June 26, 2013
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`4843-2989-0580.2
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`17
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