IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Attorney Docket No.: 4229941
`
`Customer No.: 27683
`
`§ § § § § § § § §
`
`§ § §
`
`In re Inter Partes Review of:
`
`US. Patent No. 5,632,545
`
`Issued: May 27, 1997
`
`Applicant: Dan Kikinis
`
`Application No.: 08/686,809
`
`Filed: July 26, 1996
`
`Title: Enhanced Video Projection System
`
`PETITIONER POWER OF ATTORNEY PURSUANT TO 37 CFR 42.10(b)
`FOR PETITION FOR INTER PAR TES REVIEW
`
`Petitioner Xilinx, Inc. hereby appoints the Practitioner(s) associated with Customer Number
`
`27683, as its attomey(s) to prosecute and to transact all business in the Patent Trial & Appeal Board of the
`
`United States Patent and Trademark Office connected with the above-identified petition for Inter Partes
`
`Review.
`
`Please direct all communication regarding this Petition to Customer Number 27683:
`
`David L. McCombs
`
`HAYNES AND BOONE, LLP
`
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Phone: (214) 651—5533
`Fax: (214) 200—0853
`
`The undersigned is authorized to sign this Power of Attorney on behalf of the Petitioner.
`-
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`on the
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`
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`
`Executed at
`
`35m $086 I CA
`
`day offlQ‘ctfiber, 2012.
`
`Xilinx, Inc. By:
`
`SCOILI
`Printed Name:
`Title:
`l/MC ?f€.§{O/l’/Vt‘(
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`
`

`

`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re patent of Kikinis
`
`US. Patent N0. 5,632,545
`
`Issued: May 27, 1997
`
`Title: ENHANCED VIDEO
`
`PROJECTION SYSTEM
`
`000000000000000000000000000
`
`Petition for Inter Partes Review
`
`Attorney Docket No.:
`Customer No.:
`
`42299.41
`27683
`
`Real Party in Interest: Xilinx, Inc.
`
`PETITION FOR INTER PARTES REVIEW
`
`Mail Stop Inter Partes Review
`Commissioner for Patents
`
`PO. Box 1450
`
`Alexandria, VA 22313—1450
`
`Dear Sir:
`
`Pursuant to the provisions of 35 U.S.C. §§ 311-319, Xilinx, Inc.
`
`(“Petitioner”) hereby petitions the Patent Trials and Appeals Board to institute an
`
`Inter Partes Review of claims 1-3 (all claims) of United States Patent N0.
`
`5,632,545 (“the ’545 Patent,” Exhibit XLNX—1001), which issued on May 27,
`
`1997, to Dan Kikinis, resulting from a patent application no. 08/686,809 filed on
`
`July 26, 1996. According to USPTO records, the ’545 Patent is assigned to
`
`Intellectual Ventures I LLC.
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`W
`
`I. Mandatory Notices ............................................................................................... 1
`
`A. Real Party—in-Interest................................................................................. 1
`
`B. Related matters .......................................................................................... 1
`
`C. Lead and Back—up Counsel and Service Information ............................... 1
`
`II. Grounds for Standing ........................................................................................... 1
`
`III. Relief Requested .................................................................................................. 1
`
`IV. Reasons for the Requested Relief ........................................................................ 2
`
`A.
`
`Summary of Petition .................................................................................. 2
`
`1.
`
`Background of ’545 Patent ........................................................................ 2
`
`Flasck Anticipates the Claims of The ’545 Patent and Renders Them
`2.
`Obvious .............................................................................................................. 5
`
`3.
`
`Takanashi Renders the Claims of The ’545 Patent Obvious ..................... 7
`
`B.
`
`Identification of Challenges .................................................................... 11
`
`1
`
`2
`
`3.
`
`C
`
`1.
`
`2.
`
`Challenged Claims ................................................................................... 11
`
`Statutory Grounds for Challenges ........................................................... 11
`
`Claim Construction .................................................................................. 12
`
`Unpatentability of Claims 1-3 Of ’545 Patent ........................................ 12
`
`Challenge #1: Anticipation by US. 5,108,172 to Flasck ....................... 12
`
`Challenge #2: Obviousness in View Of U. S. 5, 108,172 to Flasck ........ 19
`
`Challenge #3: Invalidity over U. S. 5,264,951 to Takanashi and U. S.
`3.
`5,287,131 to Lee ............................................................................................... 23
`
`D. Challenge #4: Invalidity over US. 5,264,951 to Takanashi, US.
`5,287,131 to Lee, and US. 5784038 to Irwin ......................................... 30
`
`V. Conclusion ......................................................................................................... 32
`
`_ii_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`I.
`
`Mandatory Notices
`
`A.
`
`Real Party-in-Interest
`
`The real party-in—interest is Xilinx, Inc.
`
`B.
`
`Related matters
`
`None.
`
`C.
`
`Lead and Back-up Counsel and Service Information
`
`Lead Counsel
`
`Back-up_ Counsel
`
`David L. McCombs
`HAYNES AND BOONE, LLP
`
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Thomas B. King
`HAYNES AND BOONE, LLP
`
`2323 Victory Ave. Suite 700
`Dallas, TX 75219
`
`Phone: (214) 651—5533
`
`Fax: (214) 200-0853
`
`Phone: (949) 202-3059
`
`Fax: (214) 200—0853
`
`ipdocketing@haynesboone.com
`
`ipdocketing@haynesboone.com
`
`USPTO Customer No. 27683
`
`USPTO Customer N0. 27683
`
`USPTO Reg. No. 32,271
`
`USPTO Reg. No. 69,721
`
`11.
`
`Grounds for Standing
`
`Petitioner certifies that it is not estopped or barred from requesting inter
`
`partes review of the ’545 Patent. The ’545 Patent issued more than 9 months ago
`
`and was not the subject of a post—grant review.
`
`111. Relief Requested
`
`Petitioner asks that the Board review the accompanying prior art and
`
`analysis, institute a trial for Inter Partes Review of Claims 1-3 of the ’545 Patent,
`
`and cancel those claims as invalid under 35 U.S.C. §§ 102 and 103.
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`IV. Reasons for the Requested Relief
`
`A.
`
`Summary of Petition
`
`The ’545 Patent describes a system that uses liquid crystal display (“LCD”)
`
`technology to create a digital video projection. At a high level, this system shines
`
`colored light beams through LCD arrays, creating multiple image light beams.
`
`Each image light beam represents a color component of the complete video image
`
`(e.g., red, green, and blue). The system then combines these component light
`
`beams into a composite image light beam suitable for viewing.
`
`This system was not new in mid-1996 when the application leading to the
`
`’545 Patent was filed. Petitioner has identified several earlier patents that describe
`
`this light—combining video—projection system. These prior art patents both describe
`
`the claimed system in full and render it obvious. Specifically, U.S. Patent No.
`
`5,108,172 to Flasck anticipates claims 1-3, or, in the alternative, renders them
`
`obvious. Claims 1—3 are also rendered obvious in view of U.S. Patent No. U.S.
`
`5,264,951 to Takanashi and U.S. 5,287,131 to Lee. Claims 2-3 are further
`
`rendered obvious in view of Takanashi, Lee, and further in view of U.S. 5,784,038
`
`to Irwin.
`
`1.
`
`Background of ’545 Patent
`
`The ’545 Patent issued on May 27, 1997 on an application filed by Dan
`
`Kikinis on July 26, 1996. (Ex. XLNX1001 (“the ’545 Patent”).) The ’545 Patent
`
`does not claim priority to an earlier application. (Id.) The patent office issued a
`
`_2_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`notice of allowability on November 25, 1996, without rejecting or objecting to any
`
`of the claims in the original application. (XLNX-1008 at Notice of Allowability.)
`
`The ’545 Patent has one independent claim and two dependent claims. (’545
`
`Patent, 4: 12-38.) The ’545 Patent also has one figure. The following claim chart
`
`illustrates claim 1 by mapping the claim language to the projection system shown
`
`in Figure 1 of the ’545 Patent:
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`’545 Patent Claim 1
`
`l. A video projector system
`comprising:
`
`individual light sources, one each
`for each color to be projected,
`adapted to provide each a separate
`light beam;
`
`a lens system in the path of the
`separate light beams, adapted for
`focusing the beams;
`
`a number of individual color filters
`
`equal to the number of beams, in the
`colors to be projected, and placed
`
`one each in each beam path;
`
`a 1g t—s utter matrix system
`comprising a number of equivalent
`switching matrices equal to the
`number of beams and placed one
`each in the beam paths;
`
`a video controller adapted for
`controlling the light—shutter
`matrices; and
`
`an optical combination system
`adapted for combining the several
`beams into a single composite beam
`for projection on a surface to
`provide a video display;
`
`wherein each beam passes through a
`color filter before being processed
`by a light—switching matrix.
`
`System Overview
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`As shown above, the ’545 Patent claims a video projection system having
`
`multiple light sources (A). These light sources create beams that are focused by a
`
`lens system (B) before entering the color filters (C, G). The light beams then enter
`
`the light shutter matrix system (D). The ’545 Patent teaches that an LCD array is
`
`one example of a light shutter matrix. (’545 Patent, 422—3). The LCD/light shutter
`
`array receives image information from a video controller (E), and encodes that
`
`information onto the light beams. Finally, the light beams are recombined by a
`
`mirror and prism system (F) into a single composite image beam that is ready for
`
`projection on a surface.
`
`Flasck Anticipates the Claims of The ’545 Patent and
`2.
`Renders Them Obvious
`
`The ’545 Patent is anticipated and rendered obvious by US. Patent No.
`
`5,108,172 to Flasck. As shown below, Flasck teaches the light—combining
`
`projection system claimed by the ’545 Patent. The following claim chart compares
`
`claim 1 of the ’545 Patent to Figures 11 and 2C of Flasck.
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`’545 Patent Claim 1
`
`l. A video projector system
`comprising:
`
`individual light sources, one each
`for each color to be projected,
`adapted to provide each a separate
`light beam;
`
`a lens system in the path of the
`separate light beams, adapted for
`focusing the beams;
`
`a number of individual color filters
`
`equal to the number of beams, in the
`colors to be projected, and placed
`
`a 1g t—s utter matrix system
`comprising a number of equivalent
`switching matrices equal to the
`number of beams and placed one
`each in the beam paths;
`
`a video controller adapted for
`controlling the light—shutter
`matrices; and
`
`an optical combination system
`adapted for combining the several
`beams into a single composite beam
`for projection on a surface to
`provide a video display;
`
`wherein each beam passes through a
`color filter before being processed
`by a light—switching matrix.
`
`
`
`one each in each beam path;
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`As shown above, Flasck discloses all of the elements of the enhanced video
`
`projection system claimed by the ’545 Patent. Three light sources (A) generate
`
`light beams. These light beams pass through color filters (C, G) 124, 126, or 128.
`
`(Flasck, 7:64-66 (“[t]he separate light sources again require the respective B, G
`
`and R filters 124, 126, and 128 to provide the B, G and R. [sic] light
`
`components.”)) The color-tinted light beams then enter the “image plane modules”
`
`shown as 92, 104, or 112 on Figure 11 (B, D). Figure 2C shows the internal
`
`workings of these image plane modules. For each image plane module, the light
`
`first passes through a lens system (B) that focuses the light. The light then passes
`
`through other components and eventually reaches an LCD panel (D), which is a
`
`light shutter matrix. The LCD panel encodes the color-tinted light beams with
`
`image information from the interface (E). Finally, the color images from each of
`
`the image plane modules are combined by a prism/mirror system (F) to create a
`
`composite image beam for viewing.
`
`The Flasck video projection system invalidates the claims of the ’545 Patent,
`
`as explained in further detail below and in the attached Buckman Declaration
`
`(Exhibit XLNX— 1006).
`
`3.
`
`Takanashi Renders the Claims of The ’545 Patent Obvious
`
`U.S. Patent No. U.S. 5,264,951 to Takanashi also renders the claims of the
`
`’545 Patent obvious in combination with other references. As shown below,
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`Takanashi in combination with Lee teaches the light—combining Video projection
`
`system claimed by the ’545 Patent. The following claim chart compares claim 1 of
`
`the ’545 Patent to Figure 17 of Takanashi and Figure 2 of Lee. As shown below,
`
`the combination of the left half of Lee Figure 2 and the right half of Takanashi
`
`Figure 17 would contain all elements of the claimed invention.
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`’545 Patent Claim 1
`
`l. A video projector system
`comprising:
`
`individual light sources, one each
`for each color to be projected,
`adapted to provide each a separate
`light beam;
`
`a lens system in the path of the
`separate light beams, adapted for
`focusing the beams;
`
`a number of individual color filters
`
`a 1g t-s utter matrix system
`comprising a number of equivalent
`switching matrices equal to the
`number of beams and placed one
`each in the beam paths;
`
`a video controller adapted for
`controlling the light-shutter
`matrices; and
`
`an optical combination system
`adapted for combining the several
`beams into a single composite beam
`for projection on a surface to
`provide a video display;
`
`SLMtr l2
`
`equal to the number of beams, in the
`colors to be projected, and placed
`one each in each beam path;
`Takanashi Figure 17 (upper image) and Lee Figure 2 (lower image)
`II
`ECBtr
`PLZ'
`
`wherein each beam passes through a
`color filter before being processed
`by a light-switching matrix.
`
`
`
`
`'ARATIONOPTICAL
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`As shown in the figures above, the combination of Takanashi and Lee teaches all
`
`of the elements of the enhanced video projection system claimed by the ’545
`
`Patent. In particular, the combination of the right half of Takanashi and the left
`
`half of Lee renders claims 1-3 obvious. First, Takanashi teaches a projector system
`
`that uses a single light source to generate three colored light beams. The three
`
`colored light beams are processed by a light—shutter matrix (D) that includes liquid
`
`crystal elements ECBtr, ECBtg, ECBtb, polarizing elements PL2r, PL2g, PL2b,
`
`and spatial light modulator elements SLMtr, SLMtg, SLMtg. The light—shutter
`
`matrix (D) encodes the color light beams with image information. The encoded
`
`color light beams pass to a three-color combination optical system (F) where they
`
`are combined to create a single composite image beam for projection. Although
`
`Takanashi does not teach the use of separate light sources for this light—combining
`
`system, another prior art reference, Lee teaches using three light sources (A) 26 to
`
`generate three light beams. These light beams pass through lenses (B) 15R, 15G,
`
`and 15B and are focused on color filters (C, G) 28R, 18G, and 18B to produce
`
`three colored light beams. The light shutter (D) 14R, 14G, and 14B encodes the
`
`three colored light beams with image information from the controller (E) 19.
`
`The Takanashi and Lee combination invalidates the claims of the ’545
`
`Patent, as explained in further detail below and in the attached Buckman
`
`Declaration (Exhibit XLNX-1006).
`
`_10_
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`B.
`
`Identification of Challenges
`
`Petitioner Challenges the validity of Claims 1-3 of the ’545 Patent as follows:
`
`1.
`
`Challenged Claims
`
`Claims 1-3.
`
`2.
`
`Statutory Grounds for Challenges
`
`Challenge 1: Claims 1—3 of the ’545 Patent are anticipated under 35 U.S.C.
`
`§ 102(b) by US. Patent No. 5,108,172 to Flasck (Exhibit XLNX-1002). Flasck
`
`was filed on September 24, 1990, and issued on April 28, 1992, and thus is prior
`
`art to the ’545 Patent at least under 35 U.S.C. § 102(b).
`
`Challenge 2: In the alternative, Claims 1-3 of the ’545 Patent are obvious
`
`under 35 U.S.C. § 103(a) over US. Patent No. 5,108,172 to Flasck (Exhibit
`
`XLNX—1002).
`
`Challenge 3: Claims 1—3 of the ’545 Patent are also obvious under 35
`
`U.S.C. §103(a) in view of US. 5,264,951 to Takanashi (Exhibit XLNX-1003) and
`
`US. 5,287,131 to Lee (Exhibit XLNX-1004). Takanashi was filed on November
`
`23, 1992, and issued on November 23, 1993, and thus is prior art to the ’545 Patent
`
`at least under 35 U.S.C. § 102(b). Lee was filed on November 25, 1992, and
`
`issued on February 15, 1994, and thus is prior art to the ’545 Patent at least under
`
`35 U.S.C. § 102(b).
`
`_11_
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`Challenge 4: Claims 2—3 are also rendered obvious under 35 U.S.C. §103(a)
`
`in view of Takanashi, Lee, and further in view of US. 5,784,038 to Irwin (Exhibit
`
`XLNX—1005). Irwin was filed on October 24, 1995, and issued on July 21, 1998,
`
`and thus is prior art to the ’545 Patent at least under 35 U.S.C. § 102(e).
`
`Petitioner requests that the Board accept each of these challenges and cancel
`
`claims 1-3 of the ’545 Patent.
`
`3.
`
`Claim Construction
`
`This petition presents the following claim analysis in a manner that is
`
`consistent with the broadest reasonable interpretation consistent with the
`
`specification. See 37 C.F.R. § 42.100(b). Petitioner reserves the right to advocate
`
`a different claim interpretation in district court or any other forum if necessary.
`
`C.
`
`Unpatentability of Claims 1-3 Of ’545 Patent
`
`The charts below show where each element of claims 1—3 is found in the prior
`
`art relied upon.
`
`1.
`
`Challenge #1: Anticipation by US. 5,108,172 to Flasck
`
`Claims 1-3 are anticipated over Flasck as set forth below:
`
`
`
`Claim Challenge #1: Analysis of Flasck
`
`(Flasck, 1:13-15.)
`
`[1.0] A video Flasck teaches a projection system:
`projector
`
`system
`comprising:
`
`The invention relates generally to projection systems
`and more particularly to an improved active matrix
`reflective image plane module and projection system.
`
`_12_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasck
`
`Flask further teaches that projection systems are designed to
`operate from a “video or computer signal source.” (Flasck, 4:9-
`10.) Thus, Flasck’s projection system is a “video projector system”
`as recited in the claim. (See Exhibit XLNX-1007, Declaration of
`
`Bruce Buckman (“Buckman”) ‘1[ 18.)
`
`[1.1]
`individual
`
`light sources,
`one each for
`
`each color to
`
`be projected,
`adapted to
`provide each
`
`a separate
`light beam;
`
`Flasck teaches three individual light sources 144, 146, & 148:
`
`The color projection system 142 again includes the three
`color reflective image plane modules 92, 104, and 112,
`but each reflective image plane module now includes its
`own light source 144, 146, and 148. The separate light
`sources again require the respective B, G, and R filters
`124, 126 and 128 to provide the B, G, and R light
`
`components.
`
`(Flasck, 7.60-66.)
`
`As further illustrated in Fig. 11, each light source provides a
`separate light beam. (See Buckman ‘][ 19.) The light beams are for
`the colors red, green, and blue (the three colors to be projected):
`4.?
`
`.93
`
`fit.
`
`A?! «45:44:
`
`//42
`
`241$
`PIA/{2770.47
`eff/Pt???
`
`_13_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasck
`
`As shown in Fig. 11, three “reflective image plane modules 92,
`[1.2] a lens
`104, and 112” (Flask, 7:61—62) lie in the path of the three separate
`system in the
`light beams. Flasck illustrates details of a reflective image plane
`path of the
`separate light module in Fig. 2C and teaches that each image plane module
`beams,
`includes a lens system to focus the light beams:
`adapted for
`focusing the
`beams;
`
`Referring to FIGS. 2A, 2B and 2C.... The light is
`columnated sic b
`a lens 34 and condensed or
`
`focused by a lens 36 to the reflective image plane
`module 30.
`
`
`
`The reflective ima e
`
`lane module 30 can however
`
`include the light 32 and other light directing elements
`34, 36 and 50 if desired.
`
`(Flasck, 4:65-5 :4 & 5:50—53.) (See also Buckman ‘1[ 20.)
`
`[1.3] a
`number of
`individual
`
`color filters
`
`equal to the
`number of
`
`beams, in the
`
`Flasck illustrates in Fig. 11 that each of the three light beams passes
`through a red, blue, or green color filter:
`
`The color projection system 142 again includes the three
`color reflective image plane modules 92, 104, and 112,
`but each reflective image plane module now includes its
`own light source 144, 146, and 148. The separate light
`
`_14_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasck
`
`sources again require the respective B, G, and R filters
`124, 126 and 128 to provide the B, G, and R light
`
`components.
`
`(Flasck, 7:60-66.) (See also Buckman ‘][ 21.)
`
`colors to be
`
`projected,
`and placed
`one each in
`
`each beam
`
`path;
`
`
`
`[1.4] a light-
`shutter
`
`matrix
`
`system
`comprising a
`number of
`
`Flasck teaches that the projection system includes equivalent image
`plane modules (e.g., Fig. 11 elements 92, 104, and 112) that are
`equal to the number of beams (three) and placed one each in the
`beam paths. Flasck further teaches that each image plane module
`includes an active matrix for encoding information on the light
`beam:
`
`equivalent
`switching
`matrices
`
`equal to the
`number of
`
`beams and
`
`placed one
`each in the
`
`beam paths;
`
`The reflective image plane module 30 includes a first
`mirrored wall 40 which has an aperture 42 through which
`the light passes and impinges on a back wall 44 of the
`reflective image plane module 30. The back wall 44 has
`attached thereto or is formed of a wafer based active
`
`matrix 46. The light has the information imparted to
`or encoded on it by the wafer based active matrix 46
`as it is reflected from the wafer based active matrix 46.
`
`(Flasck, 5 :9-16.)
`
`Flasck further teaches that the preferred active matrix provides
`“faster switching speeds” (Flasck, 5:36). Thus, Flasck’s active
`matrices are “switching matrices.” Flasck also teaches that three
`reflective image plane modules, with three switching matrices, can
`be combined to form a full-color projection system. (Flask, 6:65-
`7:3.) (See Buckman ‘fl 22.)
`
`[1.5] a video
`controller
`
`adapted for
`controlling
`the light-
`shutter
`
`matrices; and
`
`Flasck illustrates in Fig. 11 an interface 118: “[t]he information
`encoding is provided by an electronic interface 118 coupled to the
`reflective image plane modules 92, 104 and 112.” (Flasck, 7:32—
`34.) The electronic interface 118 is described as a “TV OR
`
`COMPUTER INTERFACE ELECTRONICS” (Flasck, Figs. 9, 11)
`
`Thus, interface 118 discloses the “video controller adapted for
`controlling the li ht-shutter matrices” as claimed. (See Buckman ‘][
`
`_15_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasck
`
`_ [
`
`Flasck illustrates in Fig. 11 a dichroic combining prism 150 used to
`combine the three light beams into a single composite beam for
`projection onto a screen:
`
`1.6] an
`optical
`combination
`
`
`
`The encoded B, G and R light components are each
`directed to a respective dichroic prism section of a
`conventional dichroic
`combining
`prism 150. The
`combining prism 150 combines the three B, G and R
`light components and outputs a single combined and
`encoded color signal 152, which is directed to a lens or
`lens system 154 and then is projected onto the screen
`98
`
`(Flasck, 7266-825.) (See also Buckman ‘1[ 26.)
`
`system
`adapted for
`combining
`the several
`
`beams into a
`.
`smgle
`composrte
`beam for
`projection on
`a surface to
`
`provide a
`video
`
`display;
`
`[1.7] wherein Flasck illustrates in Fig. 11 that each beam passes through a color
`each beam
`filter (e.g., filters 124, 126, and 128) before being processed by the
`passes
`image plane modules (e.g., 92, 104, and 112) and their respective
`through a
`switching matrices. (See Buckman ‘1[ 27.)
`color filter
`
`before being
`processed by
`a light-
`switching
`matrix.
`
`—16—
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasck
`
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`LCD arrays. reflective image plane module may be used in a monochrome
`
`FIG, 11
`
`
`[2.0] The
`
`Flasck teaches that each active matrix is preferably an LCD matrix:
`
`video
`
`projection
`system of
`claim 1
`
`wherein the
`
`light—shutter
`matrices are
`
`monochrome
`
`The reflective image plane module 30 includes a. . .wafer
`based active matrix 46. . .The wafer based active matrix is
`
`covered by an LCD or similar characteristic material,
`such as an electrophoretic material.
`
`(Flasck, 5:1 1-26.)
`
`Additionally, Flasck shows that each image plane module is used
`for only one color of light. Flasck further teaches that each
`
`projection system:
`
`Each of the above reflective image plane modules can be
`utilized as part of a monochrome projection system...
`
`(Flasck, 6:65-66.)
`
`Thus, Flasck teaches that each active matrix in each reflective
`
`image plane module as a monochrome LCD array. (See Buckman
`‘1[ 28.)
`
`[3.0] The
`video
`
`Flasck illustrates in Fig. 11 that the three light sources (e.g., 144,
`146, and 148) provide three beams.
`
`_17_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasck
`
`projector
`system of
`claim 1
`wherein
`three light
`sources
`provide three
`beams, and
`
`The color projection system 142 again includes the three
`color reflective image plane modules 92, 104, and 112,
`but each reflective image plane module now includes its
`own light source 144, 146, and 148. The separate light
`sources again require the respective B, G, and R filters
`124, 126 and 128 to provide the B, G, and R light
`components.
`Flasck, 7:60-66. (See Buckman <11 30.)
`
`Flasck teaches that red, green, and blue filters (e.g., 124, 126, and
`128) are used to provide red, green and blue light beams to the
`image plane modules (e. g., 92, 104, and 112) including the active
`matrix system:
`
`The light 86 includes all three light components fl,
`blue and green (hereinafter R, B and G).
`
`
`
`[3.1] red,
`green, and
`blue filters
`are used to
`provide red,
`green, and
`blue beams
`
`to an LCD
`
`matrix
`
`system.
`
`The color projection system 142 again includes the three
`color reflective image plane modules 92, 104, and 112,
`but each reflective image plane module now includes its
`own light source 144, 146, and 148. The separate light
`sources again require the respective B, G, and R filters
`124, 126 and 128 to provide the B, G, and R light
`
`components.
`
`(Flasck, 7:6—8 & 7:60—66.)
`
`Flasck illustrates in Fig. 11 that the red, blue, and green light beams
`pass from the colored filters124, 126, and 128 to the reflective
`image plane modules 92, 104, 112.
`
`—18—
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`Challenge #1: Analysis of Flasek
`
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`
`Further, as analyzed above in claim 2, each reflective image plane
`module preferably includes an LCD matrix:
`
`The reflective image plane module 30 includes a. . .Wafer
`based active matrix 46. . .The wafer based active matrix is
`
`covered by an LCD or similar characteristic material,
`such as an electrophoretic material.
`
`(Flasck, 5: 1 1-26.)
`
`As such, the reflective image plane modules are collectively an
`“LCD matrix system” as claimed. (See Buckman ‘1[ 30.)
`
`Thus, using red, green , and blue filters to provide red, green, and
`blue beams to the reflective image plane modules, as disclosed by
`Flask, teaches, that “red, green, and blue filters are used to provide
`red, green, and blue beams to an LCD matrix system,” as recited in
`the claim. (See Buckman ‘1[ 30.)
`
`Challenge #2: Obviousness in View Of US. 5,108,172 to
`2.
`Flasek
`
`In the alternative, Flasck renders the claims of the ’545 Patent obvious.
`
`_19_
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`As noted above, Flasck describes an “Interface 118” that controls the LCD
`
`display elements of the projection system. Petitioner submits that a person having
`
`ordinary skill in the art would recognize that Interface 118 is the claimed “video
`
`controller.” To the extent that the patent owner argues, or the Board holds, that
`
`this Interface 118 does not disclose a video controller, Flasck nevertheless renders
`
`claims 1-3 obvious to a person having ordinary skill in the art.
`
`Flasck teaches that it was known in the art to use a video drive circuit to
`
`control liquid crystal display (LCD) elements, such as the active matrices in the
`
`reflective image plane modules:
`
`A video or computer signal source (not illustrated) is coupled by a line
`18 to a video drive circuit 20. The video drive circuit 20 operates on
`the signal coupled thereto and generates the required drive signals
`coupled over a line 22 to the LCD 16. Typically the drive signals will
`be the audio, red video, blue video, green video, vertical sync, horizontal
`sync, reset and pixel clock signals. The drive signals cause the pixels of
`the LCD 16 to block or transmit light to impart the required information
`onto the light transmitted through the LCD 16 to a lens or lens system 24
`which projects the composite color picture onto the screen 26.
`
`(Flasck, 429-21.)
`
`It would have been obvious to implement the interface 118 as a video drive
`
`circuit because a person having ordinary skill in the art would have viewed the use
`
`of such video drive circuitry as a predictable use of priori art elements according to
`
`their established functions. Such an interface / video drive circuit would thus
`
`_20_
`
`

`

`Petition for Inter Partes Review of U.S. 5,632,545
`
`satisfy the “video controller adapted for controlling the light-shutter matrices” as
`
`claimed. (See Buckman M 24-25.)
`
`Claim 2 of the ’545 Patent requires a system having a monochrome LCD
`
`array as the light shutter matrix. As set forth above, Flask teaches the claimed
`
`LCD light shutter matrices inside the image plane modules discussed above.
`
`.
`
`Each of the above reflective image plane modules can be utilized as part
`of a monochrome projection system...
`
`(Flasck, 6:65-66.)
`
`To the extent that the patent owner argues, or the Board holds, that Flasck
`
`does not teach a monochrome LCD array, Flasck nevertheless renders claim 2
`
`obvious to a person having ordinary skill in the art. As described above, Flasck
`
`teaches the combination of monochrome light rays (red, green, and blue) to create
`
`a full-color composite image. Each of these monochrome light rays is associated
`
`with its own dedicated set of system components, including an LCD array inside
`
`the reflective image plane module. (Flasck, Figs. 2C, 11). As cited above, a given
`
`image plane module can be utilized as part of a “monochrome projection system.”
`
`Thus, to the extent Flasck does not teach “monochrome LCD arrays” in the system
`
`of Figure 11, a person having ordinary skill in the art would be motivated by
`
`Flasck and from their experience developing optical video systems to implement
`
`the reflective image plane modules using monochrome LCD arrays. (Buckman ‘][
`
`29).
`
`_21_
`
`

`

`Petition for Inter Partes Review of US. 5,632,545
`
`The following chart sets forth the evidence supporting Petitioner’s argument
`
`that Flasck renders obvious claims 1-3 of the ’545 Patent.
`
`Challenge #2: Analysis of Flasck
`
`[1.0]-[1.4]
`
`See Challenge #1, [I.0]-[I.4] above
`
`[1.5] a video Flasck illustrates in Fig. 11 an “electronic interface 118 coupled to
`controller
`the reflective image plane modules 92, 104 and 112.” (Flasck, 7:32—
`adapted for
`34.) The electronic interface 118 is described labeled in Fig. 9 as
`controlling
`“TV OR COMPUTER INTERFACE ELECTRONICS.”
`the light-
`shutter
`
`Flasck further teaches that it was known in the art to use a video
`
`
`
`matrices; and
`
`drive circuit to control liquid crystal display (LCD) elements, such
`as the active matrices in the reflective image plane modules:
`
`A video or computer signal source (not illustrated) is
`coupled by a line 18 to a video drive circuit 20. m
`video drive circuit 20 operates on the signal coupled
`thereto and generates the reguired drive signals
`coupled over a line 22 to the LCD 16. Typically the
`drive signals will be the audio, red video, blue video,
`green video, vertical sync, horizontal sync, reset and
`pixel clock signals. The drive signals cause the pixels of
`the LCD 16 to block or transmit light to impart the
`required information onto the light transmitted through
`the LCD 16 to a lens or lens system 24 which projects
`the composite color picture onto the screen 26.
`
`(Flasck, 4:9-21.)
`
`It would have been obvious to implement the interface 118 as a
`video drive circuit, which would satisfy the “video controller
`adapted for controlling the light—shutter matrices” as claimed. (See