`
`In re patent of Kikinis
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`U.S. Patent No. 5,632,545
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`Issued: May 27, 1997
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`Title: ENHANCED VIDEO
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`PROJECTION SYSTEM
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`Exhibit XLNX-1006
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`accompanying
`Petition for Inter Partes Review
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`Attorney Docket No.:
`Customer No.:
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`42299.41
`27683
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`Real Party in Interest: Xilinx, Inc.
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`O0J0OOOOO€0'JO0'><'0'J<0'D<4O'3<0"-‘
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`Declaration of A. Bruce Buckman, Ph.D.
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`Under 37 C.F.R. § 1.68
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`I, Dr. A. Bruce Buckman, do hereby declare:
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`1.
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`I am making this declaration at the request of Xilinx in the matter of
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`the Inter Partes Review of US Patent No 5,632,545 (“the ’545 Patent”) to Kikinis.
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`2.
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`I am being compensated for my work in this matter. My
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`compensation in no way depends upon the outcome of this proceeding.
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`3.
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`In the preparation of this declaration, I have studied:
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`(1)
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`The ’545 Patent, XLNX-1001;
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`(2)
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`US Patent No. 5,108,172 (“Flasck”), XLNX—1002;
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`(3)
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`US Patent No. 5,264,951 (“Takanashi”), XLNX-1003;
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`(4)
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`US Patent No. 5,287,131 (“Lee”), XLNX—l004; and
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`(5)
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`US Patent No. 5,784,038 (“Irwin”), XLNX-1005.
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`4.
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`In forming the opinions expressed below, I have considered:
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`(1)
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`The documents listed above,
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`(2)
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`The relevant legal standards, including the standard for obviousness
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`provided in KSR International Co. v. Teleflex, Inc., 550 U.S. 398 (2007), and
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`any additional authoritative documents as cited in the body of this
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`declaration, and
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`(3) My knowledge and experience based upon my work in this area as
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`described below.
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`Qualifications and Professional Experience
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`5.
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`My qualifications are set forth in my curriculum vitae, a copy of
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`which is provided as Exhibit XLNX-1007. As set forth in my curriculum Vitae, I
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`have over 44 years of experience in Electrical Engineering, including optical
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`engineering.
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`6.
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`My 44 years of experience in optical engineering includes over 15
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`years of teaching a graduate course in fiber and guided-wave optics at the
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`University of Texas at Austin, where I held the ranks of associate professor and
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`professor from 1974 until my retirement in 2009. Course topics included many of
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`the components that appear in the ‘S45 Patent, such as filters, prisms and lenses for
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`redirecting light rays, and dichroic elements for combining or splitting light of
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`different wavelengths or colors. I authored a textbook, Guided- Wave Photonics as
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`an aid in teaching the course.
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`I concurrently conducted research in optical systems
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`that resulted in dozens of peer-reviewed publications, including one on a 6-Degree
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`of freedom non-contact optical position sensor that won the Best Paper Award at
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`an international conference in 1994. I am a coinventor on a US Patent for that
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`device, and an inventor on three other patents covering various optical systems.
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`I
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`have consulted for several companies on optical technology. I have also served as
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`an expert witness in several litigations involving optical systems by preparing
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`declarations and expert reports as well as providing deposition, Markman hearing,
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`and trial testimony.
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`7.
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`I am familiar with the knowledge and capabilities one of ordinary skill
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`in the optical design arts in the period around 1996. Specifically, my work (1) with
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`students, undergraduates as well as masters and Ph.D. candidates, (2) with
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`colleagues in academia, and (3) with engineers practicing in industry allowed me
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`to become personally familiar with the level of skill of individuals and the general
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`state of the art. Unless otherwise stated, my testimony below refers to the
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`knowledge of one of ordinary skill in the optical design arts during the 1995-1997
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`time period, including the priority date of the ’545 Patent.
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`8.
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`In my opinion, the level of ordinary skill in the art for the ’545 Patent
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`is a bachelor’s degree in electrical engineering or physics combined with: i)
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`coursework including at least. two semesters with a specialization in optics and/or
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`optical systems, and ii) two years of experience designing video based optical
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`systems, including designing optical systems with off the shelf parts..
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`Relevant Legal Standards
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`9.
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`I have been asked to provide my opinions regarding whether the
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`claims of the ’545 Patent are anticipated or would have been obvious to a person
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`having ordinary skill in the art at the time of the alleged invention, in light of the
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`prior art. It is my understanding that, to anticipate a claim under 35 U.S.C. § 102,
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`a reference must teach every element of the claim. Further, it is my understanding
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`that a claimed invention is unpatentable under 35 U.S.C. § 103 if the differences
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`between the invention and the prior art are such that the subj ect matter as a whole
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`would have been obvious at the time the invention was made to a person having
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`ordinary skill in the art to which the subject matter pertains.
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`I also understand that
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`the obviousness analysis takes into account factual inquiries including the level of
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`ordinary skill in the art, the scope and content of the prior art, and the differences
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`between the prior art and the claimed subject matter.
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`10.
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`It is my understanding that the Supreme Court has recognized several
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`rationales for combining references or modifying a reference to show obviousness
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`of claimed subject matter. Some of these rationales include the following:
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`combining prior art elements according to known methods to yield predictable
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`results; simple substitution of one known element for another to obtain predictable
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`results; a predictable use of prior art elements according to their established
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`functions; applying a known technique to a known device (method, or product)
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`ready for improvement to yield predictable results; choosing from a finite number
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`of identified, predictable solutions, with a reasonable expectation of success; and
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`some teaching, suggestion, or motivation in the prior art that would have led one of
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`ordinary skill to modify the prior art reference or to combine prior art reference
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`teachings to arrive at the claimed invention. My analysis of the" ’545 Patent is set
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`forth below.
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`Background Of ’545 Patent
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`11.
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`The ’545 Patent relates to an “Enhanced Video Projection System.”
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`(’545 Patent, Title) Specifically, the ’545 Patent teaches a system that combines
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`separate light beams into an enhanced projectable beam wherein the color spots are
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`superimposed, rather than side-by—side. (’545 Patent, Abstract). To do this, the
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`’545 Patent uses separate light sources to create separate light beams, which then
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`pass through color filters and Liquid Crystal Display (“LCD”) arrays before they
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`are combined into the projectable light beam. (Id.; see also ’545 Patent at 1:64-65)
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`The following figure from the ’545 illustrates this system:
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`12.
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`The ’545 Patent has three claims, which are reproduced below:
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`1. A video projector system comprising:
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`individual light sources, one each for each color to be projected,
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`adapted to provide each a separate light beam;
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`a lens system in the path of the separate light beams, adapted for
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`focusing the beams;
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`a number of individual color filters equal to the number of beams, in
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`the colors to be projected, and placed one each in each beam path;
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`a light—shutter matrix system comprising a number of equivalent
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`switching matrices equal to the number of beams and placed one
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`each in the beam paths;
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`a video controller adapted for controlling the light-shutter matrices;
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`and
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`an optical combination system adapted for combining the several
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`beams into a single composite beam for projection on a surface to
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`provide a video display;
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`wherein each beam passes through a color filter before being
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`processed by a light-switchin g matrix.
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`2. The video projection system of claim 1 wherein the light—shutter
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`matrices are monochrome LCD arrays.
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`3. The video projector system of claim 1 wherein three light sources
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`provide three beams, and red, green, and blue filters are used to
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`provide red, green, and blue beams to an LCD matrix system.
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`13.
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`The application leading to the ’545 Patent was filed in July 1996. The
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`Examiner issued a first action Notice of Allowability in November 1996,
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`indicating that claims 1-3 (all the claims) were allowed. No reasons for allowance
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`were stated. The ’545 Patent issued in May 1997.
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`Summary Of Opinions
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`14.
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`In my opinion, the claims of the ’545 Patent would have been
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`anticipated or obvious to a person having skill in the art in July 1996.
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`15.
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`By mid—1996, engineers already knew how to create a light—combining
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`video projection system. For example, the “Flasck” reference, US; Patent No. US
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`5,108,172 (XLNX - 1002), describes a system in which multiple light sources
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`create light beams which pass through color filters and LCD arrays before being
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`combined into a single projectable beam. Fig. 11 of the Flasck reference illustrates
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`this system:
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`FIG. 11
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`As shown above, Flasck uses multiple light sources to create red, green, and blue
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`images. These images are then combined using a prism/mirror, and then projected
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`onto a screen. I discuss Flasck in more detail below and explain why it anticipates
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`or renders obvious the claims of the ’545 Patent.
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`16.
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`The “Takanashi” reference, US Patent No. 5,264,951 (XLNX-1003),
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`describes a similar enhanced projection system. In Takanashi, a light source is
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`used to create three beams of light, which pass through a color separator and a
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`light-shutter matrix (comprising liquid crystal elements ECB, polarizing elements
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`PL2, and spatial light modulation elements SLM) before being combined into a
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`single image, as shown below:
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`Starting on the bottom left, Fig. 17 from Takanashi shows a light source that is
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`separated into three separate light beams using the three-color separation optical
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`system, effectively creating three separate light sources—one each for red, green
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`and blue (R, G, and B, respectively). These colored light beams then pass through
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`a light—shutter matrix (ECB elements, PL2 elements, and SLM elements) to create
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`three image beams encoded with image information, which are then combined to
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`create a single, enhanced projection video image.
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`I discuss the Takanashi patent in
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`more detail below and explain why it renders the claims of the ’545 Patent obvious
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`in combination with the “Lee” reference, US Patent No. 5,287,131 (XLNX—1004),
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`and the “Irwin.” reference, US Patent No. 5,784,038 (XLNX—l005).
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`Anticipation and Obviousness Of ’545 Patent In View Of Flasck
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`17.
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`The Flasck reference is entitled “Active Matrix Reflective Image
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`Plane Module and Projection System.” Flasck was filed on September 24, 1990,
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`——9—
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`claims priority to an application dated August 11, 1989, and issued on April 28,
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`1992. It is my opinion that the claims of the ’54S Patent are anticipated or
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`rendered obvious in View of Flasck for the reasons set forth below.
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`Claim I .' A video projector system comprising:
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`18.
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`Flasck describes a “video projector system.” In The Background of
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`the Invention, Flasck notes a desire “to replace existing TV and computer
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`monitors” and describes the use of similar prior art devices to that end. (Flasck,
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`1:3 6-3 7.) Flasck fuither notes that some markets “require very large, high
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`resolution, full color and video speed imaging.” (Flasck, 2:27-29.) Flasck’s
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`disclosure and invention were directed to projection systems for both video and
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`computer signals. (Flasck, 4:9-l 1). Thus, the projection system described
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`throughout in Flasck and as specifically illustrated in Fig. 11 is a video projector
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`system.
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`individual light sources, one each for each color to be projected, adapted to
`provide each a separate light beam;
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`19.
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`Fig. 11 of Flasck shows a color projection system that includes three
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`separate light sources (144, 146, and 148):
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`As shown above, the light sources in Fig. 11 each correspond to a different color
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`and each provide a separate light beam. Thus, Flasck also teaches a system having
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`“individual light sources, one each for each color to be projected, adapted to
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`provide each a separate light beam.”
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`a lens system in the path ofthe separate light beams, adaptedforfocusing
`the beams;
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`20.
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`F lasck also describes a lens system for focusing the beams. Flasck
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`teaches the use of “color reflective image plane modules” (items 92, 104, and 112
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`in Fig. 11). F lasck illustrates such a reflective image plane module in Fig. 2C:
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`This figure shows that the Flasck reflective image plane module contains three
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`lenses (34, 36, and 50). Flasck teaches that “the light is columnated by a lens 34
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`and condensed or focused by a lens 36 to the reflective image plane module 30.
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`(Flasck, 5:1-3) (see also id. at 5:50-53 (“The reflective image plane module can .
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`.
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`include the light 32 and other light directing elements 34, 36, and 50 if desired.”))
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`Thus, each light beam path has its own lens system “adapted for focusing the light
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`beams.”
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`a number of individual colorfilters equal to the number of beams, in the
`colors to be projected, and placed one each in each beam path;
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`21.
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`Flasck teaches that “[t] he separate light sources again require the
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`respective B, G and R filters 124, 126, and 128 to provide the B, G and R. [sic]
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`light components.” (Flasck, 7:64-66). As shown in Fig. 11, these light filters 124,
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`126, and 128 are placed in the blue, green, and red light paths, respectively.
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`FIG. 11
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`Thus, Flasck also teaches a system having “a number of individual color filters
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`equal to the number of beams, in the colors to be projected, and placed one each in
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`each beam path.”
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`a light-shutter matrix system comprising a number of equivalent switching
`matrices equal to the number of beams and placed one each in the beam
`paths,‘
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`22.
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`The ’545 Patent explains that one example of “light-shutter” matrix is
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`a monochrome LCD array. (’545 Patent, 1:64-66). As discussed above, each of
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`the light paths in Flasck contains an equivalent image plane module. In turn, each
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`of the image plain modules (as illustrated by Fig. 2C) contains an LCD array,
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`which is identified as item 46 below:
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`Flasck teaches that “the wafer based active matrix 46 .
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`.
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`. is covered by an LCD or
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`similar characteristic material.” (F lasck, 5:20-26) F lasck further teaches that the
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`preferred active matrix provides “faster switching speeds” (Flasck, 5:36). Flasck
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`also teaches that three reflective image plane modules, with three equivalent
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`switching matrices, can be combined to form a full—color projection system.
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`(Flask, 6:65-7:3.) This switching LCD matrix system is a “light—shutter matrix
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`system.” Thus, Flasck also teaches a system having “a 1ight—shutte1' matrix system
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`comprising a number of equivalent switching matrices equal to the number of
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`beams and placed one each in the beam paths.”
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`a video controller adapted/br controlling the light-shutter matrices; and
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`23.
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`The ’545 Patent explains that a video controller receives a video
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`signal and “controls the three monochrome matrices 117, 118, and 119.” (‘S45
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`Patent, 3:13-17). Although Flasck does not use the phrase “video controller,” it
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`nevertheless teaches an “electronic interface 118” (also called “TV or computer
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`interface electronics 1 18”) that controls the light—shutter LCD matrices. (Flasck,
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`Figs. 9, 11) Specifically, Flasck teaches that the reflective image plane modules
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`“encode” the light beams with image information. (Flasck, 529-20) The
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`information encoding is provided by an electronic interface 118 coupled to the
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`reflective image plane modules 92, 104, and 112. (Flasck at 7:2—4.) Fig. 11
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`illustrates how the interface 118 provides information to the reflective image plane
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`modules.
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`Given the above information from Flasck, one of ordinary skill in the art
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`would have recognized that the “TV or computer interface electronics” of Flasck
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`was equivalent to the “video controller” of the ‘S45 Patent. Thus, Flasck also
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`teaches a system having “a video controller adapted for controlling the light—shutter
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`matrices.”
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`24.
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`Further, it also would have been obvious to use a video controller in
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`view of the disclosure of Flask (to the extent it might be argued that Flasck does
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`not teach a video controller). For example, Flasck discloses in a similar prior art
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`system, a video drive circuit for interfacing between a signal source and an LCD:
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`A video or computer signal source (not illustrated) is coupled
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`by a line 18 to a video drive circuit 20. The video drive circuit
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`20 operates on the signal coupled thereto and generates the
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`required drive signals coupled over a line 22 to the LCD 16.
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`Typically the drive signals will be the audio, red video, blue
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`video, green video, vertical sync, horizontal sync, reset and
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`pixel clock signals. The drive signals cause the pixels of the
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`LCD 16 to block or transmit
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`light
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`to impart
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`the required
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`information onto the light transmitted through the LCD 16 to a
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`lens or lens system 24 which projects the composite color
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`picture onto the screen 26. A monochrome projection system
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`would operate in the same manner with only one video light
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`component, rather than the separate blue, green and red video
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`signals.
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`(F lasck at 429-24.)
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`25. Based at least on 1) the passages at 7:2—4 and 429-24, and 2) the
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`position of the interface 118 in Figs. 9 and 11, it would have been obvious to a
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`person of ordinary skill in the art to implement the TV or computer interface
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`electronics 118 as a video controller adapted for controlling the image plane
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`modules (which are light-shutter matrices). Specifically, the passage at 72-4
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`explains that the interface 118 controls the image plane modules 92, 104, 112 by
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`providing information encoding. Also, a Video controller would most likely be
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`placed as shown in Figs. 9 and ll so that it can provide signals to the image plane
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`modules.
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`an optical combination system adaptedfor combining the several beams into
`a single composite beam for projection on a surface to provide a video
`display;
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`26.
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`Flasck describes a “dichroic combining prism/mirror,” that combines
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`multiple light beams into a composite beam, as illustrated below:
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`//42
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`FIG. 11
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`With respect to this figure, Flasck teaches that “[t]he combining prism 150
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`combines the three B, G and R light components and outputs a single combined
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`and encoded color signal 152, which is directed to a lens or lens system 154 and
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`then is projected onto the screen 98.” (Flasck, 821-5). Thus, Flasck teaches a
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`system having “an optical combination system adapted for combining the several
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`beams into a single composite beam for projection on a surface to provide a video
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`display.”
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`wherein each beam passes through a colorfilter before being processed by a light-
`switching matrix.
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`27.
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`As discussed above, Fig. 11 of Flasck shows color filters 124, 126,
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`and 128. (Flasck, 7:64-66) (“The separate light sources again require the
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`respective B, G and R light filters 124, 126, and 128 to provide the B, G, and R.
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`[sic] light components”) As shown in Fig. 11, these filters are located between the
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`light sources and the LCD light-switching matrices in the reflective image plan
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`modules. Thus, Flasck also teaches a system “wherein each beam passes through a
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`color filter before being processed by a 1ight—switching matrix.”
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`Claim 2. The video projection system ofclaim 1 wherein the light—shutter
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`matrices are monochrome LCD arrays.
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`28.
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`As discussed above, Flasck describes reflective image plane modules
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`which contain LCD arrays. (Flasck, 4:65—5:34) Flasck teaches that “[e]ach color
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`reflective image plane module operates on a single color component, red green or
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`blue, which then are combined on a screen or before projecting on the screen to
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`form the full color projection image.” (Flask, 2:60-64.) Flask further teaches that
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`“[e]ach of the above reflective image plane modules can be utilized as part of a
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`monochrome projection system.” (Flask, 6:65-66.) Thus, the individual LCD
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`arrays within the reflective image plane modules are “monochrome LCD arrays.”
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`29.
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`Further, in View of the above teaching of Flask, it would have been
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`obvious to one of ordinary skill in the alt to implement the LCD arrays in each
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`reflective image plane module as a monochrome LCD array (to the extent it may
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`be argued that Flasck does not disclose monochrome LCD arrays). Further,
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`implementing monochrome LCD arrays in the reflective image plane modules
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`would have been nothing more than a combination of known elements according to
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`known methods to yield predictable results.
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`Claim 3. The video projector system ofclaim I wherein three light sources
`provide three beams, and rea', green, and blue filters are used to provide
`red, green, and blue beams to an LCD matrix system.
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`30.
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`A.s discussed above, Flasck describes reflective image plane modules
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`92, 104, and 112 which contain LCD arrays. (Flasck, 4:65—5 :34) Fig. 11 of Flasck
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`shows a system having red, green, and blue light sources and filters that provide
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`light beams to the image plane modules, which contain LCD arrays:
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`As such, the image plane modules are collectively an LCD matrix system. Thus,
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`Flask also teaches that the “three light sources provide three beams, and red, green,
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`and blue filters are used to provide red, green, and blue beams to an LCD matrix
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`system.”
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`Obviousness In View Of Takanashi In View Of Lee [and Irwin}
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`31.
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`The Takanashi reference is entitled “Spatial Light Modulator
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`System.” Takanashi was filed on November 23 1992, claims priority to a Japan
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`application dated April 8, 1991, and issued on November 23, 1993. Lee was filed
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`on November 25, 1992, and issued on February 15, 1994. Irwin was filed on
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`October 24, 1995, and issued on July 21, 1998. It is my opinion that the claims of
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`the ’545 Patent are obvious in view of Takanashi in combination with Lee (and
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`Irwin to the extent that it may be argued that Takanashi does not contain an
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`adequate disclosure of a monochrome LCD array) for the reasons set forth below.
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`Claim 1: A video projector system comprising.‘
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`32.
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`Takanashi describes a “Video projector system.” For example, with
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`respect to Fig. 17, Takanashi teaches that an “optical image projected to the screen
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`by the projection lens PIL is obtained as the image having good contrast in the
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`color image of the object of the display.” (Takanashi, 16:40-42.) It would have
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`been apparent to a person having ordinary skill in the art that the projection system
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`described throughout in Takanashi and specifically illustrated in Fig. 17 is a
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`projector system that may be used to project video images onto a screen.
`
`L8
`
`6)
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`RLi
`
`PLI
`
`I!
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`ECBtr
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`S1..M1r
`
`'2
`
` PL3
`
`3
`$5
`is
`He
`Er
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`RLO
`
`PJL
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`Takanashi Fig. 17
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`33.
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`Thus, one of skill in the art would have recognized that Takanashi
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`discloses a Video projection system.
`
`individztal light sources, one each for each color to be projected, adapted to
`provide each a separate light beam;
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`34.
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`Fig. 7 of Takanashi shows that the projection system uses a single
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`light source (LS) to produce three separately colored light beams (red, blue, and
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`green). (Takanashi, 16:1-14.)
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`PL3
`
`RLo
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`PJL
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`“
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`ECBtr
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`
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`THREE-COLORSEPARATIONOPTICAL
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`
`
`
`
`
`
`
`
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`COBBINATIONIPTICALSYSTEM
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`Takanashi Fig. 17
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`35.
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`In contrast to the single-light system of Takanashi, other light
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`projection systems use three different light sources, each paired with its own color
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`filter in the path of its respective light beam. An example of such a system is
`
`shown in Lee Fig. 2 (reproduced below). As illustrated in Lee Fig. 2, three
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`individual light sources 26 each provide a separate light beam. Thus, there is one
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`light source for each color to be projected (red, blue, and green). (See Lee, 4: 14-
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`20.)
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`-21-
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`
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`178
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`Lee Fig. 2
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`36.
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`A person of ordinary skill in the art would have seen a three—light
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`source system versus a single~light source system as a simple matter of design
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`choice. Various factors that might affect such a decision include available space
`
`for the apparatus, ability to dissipate heat, cost of a prism or mirror system versus
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`cost of three separate sources with individual color filters, etc. A person of
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`ordinary skill in the art would have understood the differences between two such
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`systems and would have chosen the best one for a particular application. Further, a
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`person of ordinary skill in the art would recognize that the choice of i) a single
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`white light source illuminating color filters, or ii) three white light sources
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`illuminating color filters, essentially exhausts the possibilities for obtaining three
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`separate colored light beams from incident white light, thereby making either
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`choice obvious to try.
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`37.
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`One example modification would replace the single-source apparatus
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`of Takanashi Fig. 17 with a three—source apparatus, similar to that shown in Lee.
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`In this example, a person of ordinary skill in tlie art would have omitted the single
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`light source (LS) and the three-color separation optical system 10 in Fig. 17 of
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`Takanashi. In its stead, a person of ordinary skill would adopt a three-source
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`system that would include features similar to Lee’s sources 17/26, l.enses 15, and
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`filters 28 to provide colored light beams at each of the R, G, and B portions of
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`Takanasl1i’s liquid crystal elements ECB.
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`I do not propose a bodily incolporation
`
`of Lee’s components into Takanashi’s system, but rather, I note that a person of
`
`ordinary skill in the art would have been quite capable of replacing Takanashi’s
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`single—source apparatus with a three-source apparatus having three sources, three
`
`filters, and three lenses. Such a modification is a simple design choice, as noted
`
`above. Also, it is a combination of prior art elements according to known
`
`techniques to give predictable results.
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`a lens system in the path ofthe separate light beams, adaptedforfocusing the
`beams,‘
`
`38.
`
`Lee also describes a lens system for focusing the separate light beams.
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`Lee teaches using “focusing lenses 15R, 15G, 15B.” (Lee, 4:19-20.) The focusing
`
`lenses are “for focusing the light emitted from the respective light source[s].”
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`(Lee, 3:21-22.) As shown in Fig. 2, each light beam path has its own lens “adapted
`
`for focusing the light beams.”
`
`~23~
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`
`
`
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`Lee Fig. 2
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`39. Once a person of ordinary skill in the art had decided to use a three-
`
`source apparatus, as described above, such person would know to use a three lens
`
`system similar to that of Lee’s to focus beams from the source to components
`
`downstream. Such implementation would have been a matter of simple
`
`substitutions and common sense.
`
`a number of individual color filters equal to the number ofbeams, in the colors to
`be projected, and placed one each in each beam path;
`
`40.
`
`Lee also teaches that “in order to obtain the respective light beams of
`
`the colors red, green and blue, filters of the colors red 28R, green 28G, and blue
`
`28B” are used. (Lee, 4:16-19.) As shown in Fig. 2, the three color filters 28R,
`
`28G, and 28B, are placed in the beam paths from the three light sources and are
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`equal to the three colors (red, green, and blue) to be projected.
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`-24-
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`Lee Fig. 2
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`41.
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`Once a person of ordinary skill in the art had decided to use a three-
`
`source apparatus and the three lens system, as described above, such person would
`
`know to use three color filters, similar to that of Lee’s, to provide separate R, G,
`
`and B light beams to components downstream. Such implementation would have
`
`been a matter of simple substitutions and common sense.
`
`61 light-shutter matrix system comprising a number ofequivalent switching
`matrices equal to the number of beams and placed one each in the beam paths;
`
`42.
`
`Takanashi teaches a light—shutter matrix system comprising switching
`
`matrices (liquid crystal elements ECBtr, ECBtg and ECBtb, polarizers PL2r, PL2g
`
`and PL2b, and spatial ligh.t modulator elements SLMtr, SLMtg and SLMtb) in Fig.
`
`17. One of ordinary skill in the art would have recognized that the ECBtr, PL2r,
`
`and SLMtr elements combined are a switching matrix used to process only red
`
`beams. One of ordinary skill in the art would also have recognized that the ECBtg,
`
`PL2g, and SLMtg elements combined are a switching matrix used to process only
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`—25—
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`.
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`green beams. And, one of ordinary skill in the art would also have recognized that
`
`the ECBtb, PL2b, and SLMtb elements combined are a switching matrix used to
`
`process only blue beams.
`
`43.
`
`Further, as illustrated in Fig. 17, these elements are placed one each in
`
`the color beam paths to encode the beams with image information for display on a
`
`projection screen. (see e. g., Takanashi, 16:1-42.)
`
`LS
`
`<3’
`
`Ru
`
`PLI
`
`3
`t5
`
`ita
`
`'6;
`
`PL3
`
`RLo
`
`RM.
`
`Takanashi Fig. 17
`
`44.
`
`Thus, one of skill in the art would have recognized that Takanashi’s
`
`combination of ECB elements, polarizers PL2, and the SLM elements is a “light-
`
`shutter matrix system.”
`
`a video controller adaptedfor controlling the light—shutter matrices; and
`
`45.
`
`Takanashi teaches controlling the light—shutter matrix system (e.g.,
`
`ECB, PL2, and SLM elements) to encode the three light beams (R, G, B) with
`
`color image information, (see Takanashi 16:38-42.)
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`-26-
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`46.
`
`It would have been apparent to one of ordinary skill in the art to
`
`utilize a video controller in the embodiment of Fig. 17 of Takanashi to pass video
`
`signals to the ligl1t—shutter matrix system. In fact, the use of a video controller in a
`
`video projector system was basic, standard practice and would have been
`
`abundantly evident to even beginners in the art as a way to control a light—shutter
`
`matrix or other matrix to output spatially and temporally modulated light.
`
`47. An example of a Video controller is shown in Lee Fig. 2 at item 19.
`
`With respect to item 19, Lee notes using a “light shutter controlling circuit 19” for
`
`controlling light shutters 14R, l4G, and 14B in order to modulate the light beams.
`
`
`
`Lee Fig. 2
`
`48.
`
`In View of the teaching of Takanashi and Lee, utilizing a video
`
`controller adapted for controlling the ligl1t—shutter matrices was simply a matter of
`
`ordinary skill and common sense, not innovation. Furthermore, such an addition to
`
`Takanashi would have been obvious to try, as well as a combination of prior art
`
`elements according to known techniques to yield predictable results.
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`—27—
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`an optical combination system adaptedfor combining the several beams into
`a single composite beam for projection on a surface to provide a video
`display;
`I
`
`49.
`
`Takanashi teaches three-color combination optical system 12 that
`
`combines the several beams into a single composite beam for projection of an
`
`image on a screen.
`
`
`
`PLI THREE-COLORSEPARATION
`OPTlCAL
`
`R .
`
`L1
`
`LS
`
`6
`
`Takanashi Fig. 17
`
`50. With respect to this figure, Takanashi notes that an “optical image
`
`projected on the screen by the projection lens PJL is obtained as the image having
`
`good contrast in the color image of the object of display.” (Takanashi, 16:21-42.)
`
`Thus, it would have been obvious to use the projector system of Takanashi, which
`
`combines several beams into a composite beam, to display color video images with
`
`good contraston a screen.
`
`wherein each beam passes through a colorfilter before being processed by a light-
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`——23—
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`lgLNX-1006
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`switching matrix.
`
`51.
`
`As discussed above, Fig. 2 of Lee shows three color filters 28R, 28G,
`
`and 28B. (Lee, 4: 16-19) (“in order to obtain the respective light beams of the
`
`colors red, green and blue, filters of the colors red 28R, green 28G, and blue 28B”
`
`are used”) As shown in Fig. 2, these color filters are located between the light
`
`sources 26 and the light shutters 14R, 14G, and 14B. Thus, Lee also teaches a
`
`system “wherein. each beam passes through a color filter before being processed by
`
`a light—switching matrix.”
`
`52.
`
`Once a person of ordinary skill in the art had decided to use a three-
`
`source apparatus, the three lens system, and the three color filters, as described
`
`above, such person would know